Compliance verification activity type: Field Inspection
Team:
Regulated company: TransCanada Keystone Pipeline GP Ltd.
Operating company: TransCanada Keystone Pipeline GP Ltd.
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Safety inspection of the Keystone XL Project - Alberta Mainline. Assess field implementation of construction safety manual and project specific safety plans for ongoing construction activities and worker tasks including identification of potential hazards and appropriate controls relevant to the job tasks via hazard assessments; company implementation COVID-19 safety protocols; company oversight of contractors - monitoring, supervision and accountability; assess execution of work per applicable procedures and documented work practices.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - General Observations
Date & time of visit: 2020-10-15 16:00
Discipline: Safety Management
Categories:
Facility:
Observations:
General observations • CER inspectors observed that perimeter fencing and gates at Oyen Project Construction site appeared to be maintained in good condition with proper signage, including company and emergency contact numbers and warning signs to deter intrusion.• Parking area for project construction trailer site within perimeter fencing was well graded and aggregate applied.• CER inspectors and Indigenous Monitors were met at entrance to Project Construction site in Oyen by security staff and questioned by secutiry personal with regards to Covid-19. The secutiry staff also attempted to take everyone's temperature, but the temperature gun was not working properly. The secutiry officer recorded name, company and verbal response to the COVID questionnaire.• CER inspectors and Indigenous Monitors were asked to complete a COIVD-19 questionnaire by TC Energy once arriving at the project trailer site.• Michel's (prime contactor) delivered a Site Specific Safety Plan desgined for visitors that would be escorted at all times. Topcis covered included emergecy contact numbers, required PPE, conduct, speed limits on the ROW, and COVID Protocols.• COVID protocols include: maintain physical distance, masks required when 2 meters cannot be maintained, staying offsite if unwell.• Company representatives delivered a site specific orientation to CER staff and Indigenous monitors applicable to all work sites visited on inspection, which included a description of emergency and access information and personal responsibilities overview. This was reviewed each morning and signed by each person participating in the inspection.• CER Inspectors and Indigenous Monitors were provided a Field Level Hazard Assessment (FLHA) each morning for proposed activities on the field inspection that that was delivered by the TC Energy safety representative and prior to the inspection commencing. Each team member reviewed the hazards and signed the FLHA before departing the construction office.• Vehicles were observed by CER inspectors to be operated in a safe manner during inspection at all sites visited.• Vertical posts and rodding were observed to be capped off with protective plastic mushroom caps to protect workers from being impaled from a fall type hazard.• Rig matting placed appeared to be placed adequately and was in good condition.• Washrooms at Project Construction site were functional and all field portable toilets in field inspected were operational, clean, and equipped with sanitary hand disinfectant.• TC Energy staff that accompanied the CER inspection team provided helpful explanations of activities being performed at inspection sites, as well, workers/operators when asked explained work processes, and demonstrated competency when queried on matters pertinent to their role.
Compliance tool used: No compliance tool used
Observation 2 - HDD Road Crossing
Date & time of visit: 2020-10-20 12:45
General Observations
Observation 3 - Slip Bore
Date & time of visit: 2020-10-20 15:00
Observation 4 - TC Energy Indigenous monitoring and TK sites
Date & time of visit: 2020-10-21 11:18
General observations
Observation 5 - Access and Wash Station
Date & time of visit: 2020-10-21 12:30
Observation 6 - Track Bore
Date & time of visit: 2020-10-21 14:30
Observation 7 - Mobile Medical Unit
Date & time of visit: 2020-10-21 15:30
Mobile Medic unit was inspected and found to be well equipped. Drug record log was recorded and updated weekly.Advanced Care Paramedic RO503146 credentials were checked and validated through the Alberta College of Paramedics website.Fire extinguisher with valid inspection tags affixed to cylinder was observed.
Observation 8 - Ultrasonic Testing
Date & time of visit: 2020-10-22 10:30
Observation 9 - Backfill
Date & time of visit: 2020-10-22 12:30
General observations•Mobile equipment checked was equipped with a suitable type ABC fire extinguisher, manufacturer manual and a spill kit.• Hazard warning signage was affixed to control zone marked with yellow ribbon or fenced off with temporary fencing outside the excavated ditch area to identify and mitigate the hazard.• Vertical posts and rodding were observed to be capped off with protective plastic mushroom caps to protect workers from being impaled from a fall type hazard.
Observation 10 - Lowering-in
Date & time of visit: 2020-10-22 15:00
General observations• Foreman went over FLHA for the activity.• Mobile equipment checked was equipped with a suitable type ABC fire extinguisher, manufacturer manual and a spill kit.• Hazard warning signage was affixed to control zone marked with yellow ribbon or fenced off with temporary fencing outside the excavated ditch area to identify and mitigate the hazard.• Vertical posts and rodding were observed to be capped off with protective plastic mushroom caps to protect workers from being impaled from a fall type hazard.• CER inspectors did not observe any tears, rips or fraying on the sling of the side boom.CER inspectors confirmed TC Energy inspector had a copy of the most recent version of the lowering-in procedure.
Observation 11 - Welding
Date & time of visit: 2020-10-22 15:15
Observation 12 - CNC 1 Wheel Chocks
Date & time of visit: 2020-10-20 11:00
CER Inspection Officers observed that portable Dog House trailer tires were not chocked or had the trailer jacks down.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Company shall place wheel chocks on portable "dog house" trailer wheels to prevent movement. Company shall place wheel chocks on portable doghouse trailer.
Due date: 2020-10-21
Date closed: 2020-10-21 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 13 - CNC 2 Electrical Bond wire
Date & time of visit: 2020-10-20 11:15
CER Inspection Officers observed that electrical bond wire from storage trailer sheathing was broken and wires were frayed going to ground bar connection clamp.
Company shall replace ground bond wire from trailer to ground rod connector.
Due date: 2020-10-20
Date closed: 2020-10-20 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.
Observation 14 - CNC 3 Equipment Inspections
Date & time of visit: 2020-10-21 13:30
Excavator was moved without operator completing daily equipment check.
Company submitted to the CER Inspection Officers a photo of the daily equipment inspection for the excavator completed.
Due date: 2020-10-22
Date closed: 2020-10-22 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.
Observation 15 - CNC 4 Fire Protection
Date & time of visit: 2020-10-21 13:45
Company excavator was observed to be equipped with a fire extinguisher that had no annual inspection tag.
Company shall replace fire extinguisher on excavator with an fire extinguisher that has both a current annual inspection and October monthly inspected tag affixed to the extinguisher.
Date closed: 2020-10-23 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.
Observation 16 - Canada Labour Code Part II
Date & time of visit: 2020-10-19 10:30
CER Inspectors observed that this was a contruction type inspection and that work was being performed by contractors with Company oversight.Inspectors explained the Canada Labour Code Part II application is to employers covered by it and to their employees.
Observation 17 - Indigenous Monitor Observations - Thunderchild First Nation
Date & time of visit: 2020-10-22 12:00
Discipline: Indigenous Monitoring
Additional observations recorded by Indigenous Monitors participating in the CER inspection. Any compliance-related observations that require specific regulatory follow-up have been recorded above.
Observation 18 - Indigenous Monitor Observation - Métis Nation of Alberta
Additional observations recorded by Indigenous Monitors participating in the CER inspection. Any compliance-related observations that require specific regulatory follow-up have been recorded above.1.0 INTRODUCTION
The environmental inspection took place on the Oyen North Section of the KXL Pipeline Project between October 20-23, 2020. It was an interesting and good inspection all equipment was in excellent shape, equipment operators were very friendly and knowledgeable about their role in the pipeline construction. The proponent IMs were very friendly and knowledgeable about their job and proud of the role they played in the pipeline.
2.0 OBSERVATIONS
2.1 Archeological
Inspected archeological site TK327. The TK heritage sites along the ROW were all fenced off. The red sites cannot be disturbed. The green sites if they are on ROW can be moved
2.2 Wildlife
Returned to the Rubbing Stone area to inspect the barbed wire fence from previous inspection. The wire had not been replaced with smooth wire as requested previously. The proponent stated they were waiting on the fencing crew to change out the barb wire for smooth wire.
2.3 Safety
Meet at the proponent check point to COVID19 tested and complete the COVID19 orientation. Also completed the prime contractor and proponents safety orientation. Also acknowledged the proponents Life Saving rules and signed off.
Meet with IOs and IMs and reviewed safe driving areas and daily road conditions. Drove to Oyen to meet with the proponent, prime and IMs to discuss hazard assessment and noise before inspections. Noise safety was discussed, ear protection needed when noise reached 85 DBAs. Anything above double hearing protection required. Also discussed when planning to inspect equipment, the blades or bucket must be positioned on the ground and the machine shut down. Keep in eye contact with the equipment operator when passing, the operator will shut down the machine and put blade or bucket on the ground.Attend safety meeting with CER, and proponent to discuss safe driving, maintain space between vehicles, slips trips and falls pinch points, eye contact with equipment operators when passing machines. Inspect ultrasound pipe survey unit discuss safety hazards with operator. Inspect back filling equipment and pretrip equipment records.
2.4 Compliance
Inspected an underground HDD site. The inspection included inspecting equipment safety stickers, ground lines, discussed drill unit safety lock out, and reviewed equipment safety checklist and inspected drill records.
The inspection continued along the ROW, inspected the pipe string, hydrovac 1250 excavating under hot line . Inspected daily equipment check list, logbooks, and fire extinguisher.Inspected cleaning station LKP19-100. At the station we had a safety moment. The inspection continues along the ROW, inspected track bore being unloaded and set-up at 51a . Inspected bore. Next inspection along ROW was pipeline mitigation, to unsure it was in place. Inspect medic truck and equipment, both were in excellent condition. The medic on staff was very knowledgeable about his role, and pipeline safety. Inspected pipe backfilling equipment and maintenance records. Final inspection, drove to the lower area, safety moment before inspection. Inspecting the side boom and lowering in procedure. Inspect welding crew, welding dog house and pipe records.
3.0 SummaryIt was an interesting and good inspection all equipment was in excellent shape, and equipment operators were very friendly and knowledgeable about their role in the pipeline construction.
The IMs were very friendly and knowledgeable about their job and proud of the role they played in the pipeline.
I learned a lot and gained a lot of knowledge from the CER field compliance specialist their role in pipelines and the proponent and their role in the safety of all involved
Observation 19 - Information Request - Fencing
Discipline: Environmental Protection
CER inspectors and Indigenous Monitors observed at the site of an archeological site that the fence on the west side of the RoW and to the west side of the heritage resources feature consisted of four strings of barbed wire. TC Energy was not able to confirm if the bottom row of barbed wire was to the changed to a smooth wire to prevent potential harm to migratory animals, and if it was to be changed, when the change would occur.
Compliance tool used: Information Request (IR)
Keystone XL project (Project) notes that wildlife friendly fencing is not a requirement in theEnvironmental Protection Plan (EPP); however, during a meeting on 28 Feb 2018 with Special AreasBoard (Special Areas) and Alberta Environment and Parks (AEP), Special Areasand AEP requested thatthe Project consider wildlife friendly fencing where installation of new fence was required. The Projectcommitted to install wildlife friendly fencing in the Project area where new fence was required by theProject. Requests by landowners for typical barbed wire fencing or other fencing types will dictate thatwildlife friendly fencing may not be constructed in some areas. The Project notes that the area observedduring the inspection is located within Special Areas (Oyen 42+350). The fencing was installed withbarbed wire on the bottom prior to smooth wire being available to the contractor and will be replacedwith smooth wire prior to in-service.
Due date: 2020-11-30
Date closed: 2020-11-30 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.
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
