Compliance Verification Activity Report: CV1920-290 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2735
• Inspector 2408
• Inspector In Training T

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Damage Prevention
• Safety Management

Related events:

• CV1920-495

Rationale and scope:

Safety oversight of construction activities of NOVA Gas Transmission Ltd. (NGTL) Clearwater West Expansion Project. Field Inspection of Grande Prairie Mainline Loop No. 3 (Elmworth Section 1) and Loop No. 2 (Huallen Section). Assess compliance with the Onshore Pipeline Regulations (OPR), for the safety management program, including worker safety, contractor oversight and construction safety manuals / site specific safety plans. Observe compliance with respect to Canada Labour Code Part II, where applicable.

Compliance tool(s) used:

• Information Request (IR) (5)

Facility details

Facilities:

• GRANDE PRAIRIE MAINLINE LOOP NO. 2
• GRANDE PRAIRIE MAINLINE LATERAL LOOP #3

Facility Types

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

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Labour Code (CLC)
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• Plans And Procedures
• Project-specific plan or procedure
• TC Project No. 000657 Grande Prairie Mainline Loop No. 3 Elmworth Section 1 Revision 0 August 16, 2019
• Project-specific plan or procedure
• TC Project No. 000657 Grande Prairie Mainline Loop No. 2 Huallen Section Revision 0 August 16, 2019
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Project Yard

Date & time of visit: 2019-12-12 17:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Conveying Equipment
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Temporary Structures
• Scaffolding and Temporary Ladders
• Temporary Stairs, Ramps and Platforms
• Signage
• Training and Competency
• Training, Competency and Qualification

Facility:

• GRANDE PRAIRIE MAINLINE LOOP NO. 2 (Pipeline)

Observations:

• Upon arrival at the project yard, the CER inspection team met the company's regulatory compliance representative who was attending the daily meeting of inspectors.
• The company representative accompanied CER inspectors directing them to the orientation trailer.  
• The company required sign-in and attendance of the safety orientation for personnel and visitors to the project sites.  
• CER inspectors signed in at the orientation trailer and participated in the safety orientation delivered by contractor's Corporate Safety Manager.
• During the two-hour orientation, safety and environmental expectations, including hazards, controls and emergency procedures, were presented.
• The project yard was maintained, clean of debris, with slip resistant walking surfaces, hand rails, and designated smoking area.
• Parking areas were clearly delineated and back in parking observed.
• Electrical generators and fuel tanks were grounded.
• Concrete (Jersey) barriers were strategically placed guarding infrastructure. 
• Trailers entered were equipped with fire extinguishers, comfortably heated, free of accumulated debris, and wash/toilet facilities appeared to be adequate in number, private, sanitary, supplied, and with hot and cold running water.
• Following an opening meeting in the company trailer, CER inspector's requests for information were satisfied by documentation review, further inquiry and company representative explanation.  

Compliance tool used: No compliance tool used

Observation 2 - Elmworth Section

Date & time of visit: 2019-12-10 17:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Temporary Structures
• Scaffolding and Temporary Ladders
• Signage
• Training and Competency
• Training, Competency and Qualification

Facility:

• GRANDE PRAIRIE MAINLINE LATERAL LOOP #3 (Pipeline)

Observations:

• CER inspectors traveled in convoy led by company representatives, with vehicles equipped for travel on the pipeline construction right of way (ROW) to the Elmworth section.
• Extensive rig mats were used on traveled surfaces.
• Persons on site wore personal protective equipment (PPE) as required for the project.
• ROW and travel areas were marked.
• Sharp metal atop steel posts of barricades were capped.
• Overhead powerline crossings were well marked with signage that included the voltage and safe approach distance for the goal posts.
• CER inspectors observed that the hot line crossings, encroachments, temporary work spaces were marked appropriately.  
• Field Level Hazard Assessment (FLHA) were presented, examined and sign offs made.
• Direct Pipe Install (DPI) excavation of originating point for the planned DPI was observed to be fenced and barricaded with no entry permitted at the time. 
• Company representative briefed the CER inspectors on the planned DPI confined space entry and rescue plan.
• CER Inspectors reviewed the company contractor's "Trench Inspection and Entry Authorization Form’ and ‘Excavation Entry Sign in Sheet’ for the excavation at the planned DPI entry point that were signed by the DPI contractor foreman.
• DPI entrance was blocked and excavation barricading added by crews prior to leaving site on extended break.
• CER Inspectors looked at the TC Energy DPI inspector’s inspection report and noted that it contained observations related to safety, quality control, environment, and photos.
• CER Inspectors observed compressed gas cylinders and plastic gas cans of unknown contents stored in an unventilated sea can. The company representative working at the site told the inspectors he believed these containers to be empty. Inspectors discussed with company representatives this practice of storing of such containers, including the potential of such to lead to inadvertent storage of a container with residual hazardous substance, and that in the event an ignition source, containment of such hazardous substance in an unventilated sea can presents an explosive hazard. Company representatives removed these containers from the sea can for storage outdoors.
• CER inspectors participated in the toolbox talk and signed on to the FLHA for the activities at the location of pipe stringing activity.
• Company representatives informed CER inspectors that the bungee cords used to secure tarps covering pipe segments trucked in were removed in such a manner that it would release away from their body, and workers unhooked the bungee cords in the manner described.
• Workers folded the tarp for transport prior to reuse for the next load rather than bunch it up. 
• Workers inspected each tie down strap as it was being rolled up after being removed from the load.
• Pipe segments were removed from the truck trailer transporting them by use of the Deckhand® Pipe Handling System attachment on an excavator.
• Pipe segments were safely placed on cribbing in accordance with company standard.
• Workers properly signaled both the pipe truck driver and the deck hand operator movements.
• CER Inspectors looked at the TC Energy pipe stringing inspector’s inspection report and noted that it contained observations related to safety, quality control, environment, and photos.

Compliance tool used: No compliance tool used

Observation 3 - Huallen Section

Date & time of visit: 2019-12-11 17:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Permanent Structures
• Housekeeping
• Signage
• Temporary Structures
• Temporary Stairs, Ramps and Platforms
• Signage
• Training and Competency
• Training, Competency and Qualification

Facility:

• GRANDE PRAIRIE MAINLINE LOOP NO. 2 (Pipeline)

Observations:

• CER inspectors traveled in convoy led by company representatives, with vehicles equipped for travel on the pipeline construction right of way (ROW) to the Huallen section.
• Persons on site wore personal protective equipment (PPE) as required for the project.
• ROW and travel areas were marked.
• Sharp metal atop steel posts of barricades were capped.
• Overhead powerline crossings were well marked with signage that included the voltage and safe approach distance for the goal posts.
• CER inspectors observed that the hot line crossings, encroachments, temporary work spaces were marked appropriately.  
• Field Level Hazard Assessment (FLHA) were presented, examined and sign offs made.   
• Pipelayer Sideboom equipment was observed operating safely.
• Equipment was parked securely or with operators on board.
• Equipment examined had completed log books, spill kits and fire extinguishers.
• Pipelayer sideboom operator described his operating experience and capably demonstrated the daily pre-operation visual ‘circle check’ inspection of equipment to CER inspectors.
• Blasting crew worker wore a full face mask with supplied air.
• Coating crew worker wore a half-face masks with disposable respirator cartridges.
• A joint of pipe being was prepped for hydro-test prior to being lowered-in.
• Company representatives informed the CER inspector that the pressure vessels were certified prior to coming into the field for use.
• Temporary structure (hoarding) was being erected in order to equalize the temperature of the environment for the hydro-test.
• TC Energy craft inspector informed the CER inspector of test plan that the hydro-test steps to be used will follow, including that the area will be cleared of all unnecessary personnel and safety zone sectioned off.
• CER inspector reviewed the FLHA for the counter-bore pipe end prep.
• Crew members working at this location wore cut resistant gloves.
• Noted that all crew members were wearing the required PPE.
• All metal shards on the ROW as a result of the end prep are picked up with a magnet rake, scraped into a bucket and discarded into a scrap metal bin.
• All end prep machines had safety guards in place.
• Main gang welding equipment (side boom hauling welding shacks and excavators) crossed access road, where overhead power lines were appropriately flagged.
• Traffic management was controlled by road flagging crew present during this activity as equipment was being mobilized across the road way. 
• Welding crew inside the welding shacks wore respirators or forced air packs.
• The welding shacks were also equipped with forced air intake and exhaust.
• During the shack movement along the pipe by the side boom, tag lines were used to assist in the handling of the load.
• All welding shacks were equipped with a safety lock controlled by the welders to ensure the boom operator was unable to lift the welding shack while persons remain in the shack, and a strobe light associated with the above noted lock notifies the boom operator that the lock is engaged.
• CER inspectors were informed by company representatives of readily available ‘back-weld confined space entry’ procedure, and of permits completed each day,, since multiple back-weld confined space entries occur on a daily basis.

Compliance tool used: No compliance tool used

Observation 4 - Contractor Oversight

Date & time of visit: 2019-12-12 16:00

Discipline: Safety Management

Categories:

• Training and Competency
• Training, Competency and Qualification

Facility:

• GRANDE PRAIRIE MAINLINE LOOP NO. 2 (Pipeline)

Observations:

• CER's field inspection team met with company representatives at the project field office site in Grande Prairie, AB.
• Safety Management Program Overview including requests for documentation of process and procedures in focus areas:
• Occupational Health and Safety Standards document for contractors was observed.
• Health, Safety and Environmental Manual was observed.
• Confined Space Entry and Rescue Plan document was observed.
• CER inspectors were informed by company representatives that there are no steep slopes on the Elmworth and Huallen sections.
• Project Safety inspector presented examples of inspection reports captured using tablets, explaining that these are shared daily with foremen, reviewed at the weekly meeting, and are subject to review by company's lead inspector.
• Site Specific Safety Plans (SSSP) for the project sections were observed, and company representatives explained the review of these aimed at ensuring consistency with the company safety program. 
• Company sign-off observed on both of the SSSPs was explained as the culmination of its review.
• CER inspectors inquired of company representatives with respect to regulatory requirements for company inspection independent of the construction contractor.
• The company's project Construction Manager informed CER inspectors of the number of inspectors on site for the purpose of meeting obligations to ensure construction meets regulatory requirements, including condition compliance, and the breakdown of these by craft was discussed.
• CER inspectors inquired as to the company process for ensuring the required competency of its inspectors.
• The company's electronic Learning Management System (LMS) was described as including testing that inspectors must pass.
• CER inspectors examined the company "On-Boarding Sign-Off Sheet," a record including name, position, signature of each inspector and check-offs in eight project on-boarding areas, including: sign off of receipt of box content; environmental drawings; project specifications, plans; responsibilities; change management; communication protocols and inspection reporting requirements.  
• CER inspectors were informed of internal audit aimed at improving documenting the inspector competency verification process.
• CER inspectors were provided onboarding presentations (slides) of various lengths applicable to pipeline construction work functions, including: Pipeline Stockpile; Quality; Pipeline Stripping and Grading; Pipeline Clearing; Pipeline Welding and Preparation (105 slides); Pipeline Buoyancy Control; Pipeline Road and Utility Crossings; Pipeline Water Crossings; Hydrostatic Testing; Pipeline Hauling and Slinging; Safety; Pipeline Coating; Pipeline Trenching and Excavations; Pipeline Bending and Set Up.
• The company's construction manager described the process for vetting contractors utilizes an electronic system with task workflow and data processing.
• CER inspectors attended the group daily meeting of company inspectors led by the construction manager.
• CER inspectors conversed with company inspectors at work during construction activity in the field.

Compliance tool used: No compliance tool used

Observation 5 - Information caviardée conformément au paragraphe 144(5) du Code canadien du travail

This information has been redacted pursuant to Section 144(5) of the Canada Labour Code

Observation 6 - IR1 Compressed breathing air compressors

Date & time of visit: 2019-12-11 13:30

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Personal Protective Equipment

Facility:

• GRANDE PRAIRIE MAINLINE LOOP NO. 2 (Pipeline)

Observations:

While onsite, CER inspectors were unable to determine if the air compressors used for supplied air have been inspected as required.

Alberta OHS applies with respect to the contractor's employees (workers), as is noted in the site specific safety plans submitted as the construction safety manual under Onshore Pipeline Regulations (OPR) section 20.  The Alberta OHS Code requirement, Personal Protective Equipment, Respiratory Protective Equipment, Quality of breathing air, s. 249, states:

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 18. Construction Safety
    • (1) If a company contracts for the provision of services in respect of the construction of a pipeline, the company shall
      • (c) take all reasonable steps to ensure that construction activities are conducted in accordance with the manual developed under section 20; and

Company action required:

For the purpose of completing this inspection, provide documentation demonstrating that the company ensures its contractors' compliance to the Alberta OHS Code Part 18, Personal Protective Equipment, section 249, with respect to respiratory protective equipment.

Due date: 2020-01-13

Date closed: 2020-01-15
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 7 - IR2: Field Level Hazard Assessment Review

Date & time of visit: 2019-12-11 15:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Hazard Assessment

Facility:

• GRANDE PRAIRIE MAINLINE LOOP NO. 2 (Pipeline)

Observations:

CER inspectors were told that the TC Energy lead safety inspector routinely reviews contractors' Field Level Hazard Assessment (FLHA) for the purpose of quality assurance. CER inspectors were not able to make inquiries to the lead safety inspector as he was unable to participate in the inspection at the time inspectors were on site.  

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 54. Construction Inspection
    • (1) When a company constructs a pipeline, the company or an agent independent of any construction contractor retained by the company shall inspect the construction to ensure that it meets the requirements of these Regulations and complies with the terms and conditions of any certificate or order issued by the Board.

Company action required:

For the purpose of completing this inspection, provide the documented results of TC Energy's in depth review of the contractor's Field Level Hazard Assessments.  

Due date: 2020-01-31

Date closed: 2020-01-31
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 8 - IR3: Coating Substance - Worker Protection

Date & time of visit: 2019-12-11 13:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Personal Protective Equipment

Facility:

• GRANDE PRAIRIE MAINLINE LOOP NO. 2 (Pipeline)

Observations:

• CER inspectors observed a worker applying pipeline coating had the coating substance on the outside of the protective mask being worn.
• Another worker at the same location told CER inspectors that the mask is changed after an indication that it is getting harder to breathe through.
• Company representatives informed CER inspectors of the brand of cartridges being used and the cartridges are replaced on an as needed basis (approximately 7 days) or when they clog up.
• CER inspectors were provided with one SDS for the coating material (Product Name: SP-2888 R.G. Brush Base).
• Company representatives on site were asked if atmospheric testing has been completed in the immediate work area of the coating crew to determine if appropriate respiratory protection controls are in place, but indicated they were unable to answer this question at the time.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 18. Construction Safety
    • (1) If a company contracts for the provision of services in respect of the construction of a pipeline, the company shall
      • (c) take all reasonable steps to ensure that construction activities are conducted in accordance with the manual developed under section 20; and
  • 20.
    • (1.1) If a company contracts for the provision of services in respect of the construction of a pipeline, the construction safety manual shall set out the contractor’s responsibilities referred to in paragraph 6.5(1)(l).

Company action required:

Due date: 2020-01-31

Date closed: 2020-01-31
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 9 - IR4: Outdoor atmospheric testing - Coating

Date & time of visit: 2019-12-11 13:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Limits of Exposure

Facility:

• GRANDE PRAIRIE MAINLINE LOOP NO. 2 (Pipeline)

Observations:

• CER inspectors observed that workers who apply pipeline coating were wearing half masks with respirator cartridges.
• Company representatives on site were asked if atmospheric testing has been completed in the immediate work area of the coating crew to determine if appropriate respiratory protection controls are in place, but indicated they were unable to answer this question at the time.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 18. Construction Safety
    • (1) If a company contracts for the provision of services in respect of the construction of a pipeline, the company shall
      • (c) take all reasonable steps to ensure that construction activities are conducted in accordance with the manual developed under section 20; and
  • 20.
    • (1.1) If a company contracts for the provision of services in respect of the construction of a pipeline, the construction safety manual shall set out the contractor’s responsibilities referred to in paragraph 6.5(1)(l).

Company action required:

For the purpose of completing the inspection, provide documentation demonstrating that the company has assessed the immediate work area of the coating crew to determine if appropriate respiratory protection controls are in place.


 

Due date: 2020-01-17

Date closed: 2020-01-17
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 10 - IR5: Direct Pipe Install

Date & time of visit: 2019-12-10 13:30

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Hazard Assessment
• Temporary Structures
• Temporary Stairs, Ramps and Platforms
• Training and Competency
• Training, Competency and Qualification

Facility:

• GRANDE PRAIRIE MAINLINE LOOP NO. 2 (Pipeline)

Observations:

The Direct Pipe Installation (DPI) activity was not observable at the time of the field inspection. 
For purpose of inspection, provide a schedule with dates of the stages of the DPI, in particular the dates of worker entries into the pipe that are planned, and the purpose of each planned entry. The inspector's interest is in the DPI method, is on safety risks and controls, primarily confined space entry, as managed by the company with respect to the DPI contractor and its workers.
 

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 6.5 Management System Processes
    • (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;
  • 18. Construction Safety
    • (1) If a company contracts for the provision of services in respect of the construction of a pipeline, the company shall
      • (b.1) inform the contractor of the contractor’s responsibilities referred to in paragraph 6.5(1)(l);
  • 20.
    • (1.1) If a company contracts for the provision of services in respect of the construction of a pipeline, the construction safety manual shall set out the contractor’s responsibilities referred to in paragraph 6.5(1)(l).
  • 47. A company shall develop, implement and maintain a safety management program that anticipates, prevents, manages and mitigates potentially dangerous conditions and exposure to those conditions during all activities relating to construction, operation, maintenance, abandonment and emergency situations.

Company action required:

Provide the DPI schedule and information on the method and hazard controls during the DPI, particularly with respect to confined space entry.

Due date: 2020-01-22

Date closed: 2020-01-24
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: