Compliance Verification Activity Report: CV1920-503 - TransCanada PipeLines Limited

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2773

Regulated company: TransCanada PipeLines Limited

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• Saskatchewan

Discipline(s):

• Safety Management

Related events:

• CV1819-261
• CV1920-197

Rationale and scope:

Safety oversight of operations activities at CS 13 Caron and CS 17 Regina Compressor Stations. Verify implementation of corrective action plans from CV1819-261 (COHSR Part X and NFC Parts 3 and 4 and Part XIX Hazard Prevention Program for the compressor station). Verify compliance with CER Act, OPR regulations, CLC Part II, COHSR, and CSA Z662.

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (3)

Facility details

Facilities:

• STN 13 - CARON [LINE 100-2]
• STN 17 - REGINA [LINE 100-2]

Facility Types

• Pipeline
• Compressor station

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2016-06-14
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• Plans And Procedures
• Standard Operating Procedure or Plan (SOP)
• TEN-EL-ELGND-GLE Electrical Grounding Design Standard (CAN-US-MEX)
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - General Observations Compressor Station 13 & 17

Date & time of visit: 2020-02-11 13:10

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
• Limits of Exposure
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Overhead Cranes
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Permanent Structures
• Stairs, Fixed Ladders and Access/Egress
• Docks, Loading Ramps
• Housekeeping
• Shelving and General Storage
• Signage
• Lighting
• General Lighting
• Task Lighting
• Noise Control
• Signage
• Training and Competency
• Training, Competency and Qualification

Facility:

• STN 13 - CARON [LINE 100-2] (Facility)

Observations:

• Company representatives delivered a site specific orientation to CER staff at each site, which included a description of emergency procedures, alarm types and muster areas.
• Inspectors observed perimeter fencing and gates in good condition with proper signage affixed, including company and emergency contact numbers and warning signs to deter intrusion.
• CER inspectors observed that company personnel wore required personal protective equipment (PPE).
• Inspectors observed good housekeeping: floors clear of tripping hazards; equipment and tools properly stored; waste material segregated; garbage in proper bins and not over filled.
• CER inspectors observed stationary grinders and drill presses were secured to the floor and face shields were readily available.
• Two hand held grinders were observed by CER staff to be fitted with guards, appropriately rated discs, and were double insulated.
• Inspectors observed flammable storage cabinets that were of manufactured type, in good condition, and were equipped with bungs in place. 
• Battery areas were inspected by CER staff and found to be neat and tidy, with protected plexi-glass installed to protect from outward working area.
• Inspectors observed compressed nitrogen gas cylinders, guages off, that were stored upright with caps on and chained or strapped to permanent structure wall bracket or railing.
• Extension and step ladders observed by CER staff were safely stowed such that they did not pose a tripping hazard or danger from falling.
• Inspectors noted that portable fire extinguishers of appropriate type were placed near doors and egress ways and affixed tags had up to date inspections and maintenance recorded.
• Emergency equipment inspected by CER staff, including both eyewash bottles and stations, had up to date inspections recorded on affixed tags.
• Inspectors observed that washrooms were equipped with sanitary supplies, in good condition, and were clean.
• Company representatives indicated gas monitoring equipment is calibrated on site (using pentane as a reference gas) and bumped daily.
• Elevated walkways observed by CER staff were of grated slip resistant design, equipped with secure guardrails and handrails.
• Driveways and parking areas observed by CER staff were graded with sufficient aggregate applied.
• Company representatives informed CER inspectors that the company's requirement for a positive air shut off (PASO) on diesel engines entering a facility was in place and confirmed prior to vehicle entry into hazardous locations.
• CER Inspectors observed a safety bulletin board was visible near the lunch room at both Caron and Regina stations. Information posted on the board included the emergency response plan, parking and site traffic plan, and hazard bulletins. For example, an internal hazard bulletin from December 2019 related to lockout and tagout procedures was observed posted at both stations.
• Critical infrastructure was protected by placing of concrete barriers to mitigate potential of equipment/vehicle unintentional contact with site infrastructure, and company representatives stated that spotters are used in accordance with the company's spotter program.
• CER staff observed pipe assemblies were marked by labeling to identify product and direction of flow.
• Overhead and jib cranes were observed by inspectors to have inspection and maintenance records documented at the required frequency.
• Vehicles were observed by CER staff to be operated in a safe manner during the inspection at all sites.
• Mobile equipment observed by CER inspectors appeared to be in good condition and was parked securely, and operator logbooks were onboard and found to be complete, with signed entries of pre-use checks.
• Mobile equipment observed by CER staff had suitable type ABC fire extinguisher and Positive Air Shutoff switch (PASO) switch.
• Buildings visited during the inspection had hazard warning signage on building entry doors and first aid signs at stations.
• CER Inspectors observed machine guards in place on rotating equipment, including a portable compressor.
• Industrial shelving storage observed by CER inspectors was shelf load rated, was secured to floor, and there appeared to be no overloading of shelves.
• CER observed containers of hazardous substances were labeled, including drums, pails and jugs.
• Hazardous waste storage areas observed by CER Inspectors had appropriate secondary containment and was organized and tidy.
• Employees accompanied the CER inspection team, providing helpful explanations of work processes, and demonstrated competency when queried on matters pertinent to their role.

Compliance tool used: No compliance tool used

Observation 2 - 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 3 - CNC 1 - electrical grounding (Compressor Station 13)

Date & time of visit: 2020-02-11 14:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Electrical Safety
• Flammable and Combustible Liquids

Facility:

• STN 13 - CARON [LINE 100-2] (Facility)

Observations:

CER staff observed flammable liquid safety cabinets in the paint room of Caron Station that were not bonded to ground. 

TC Energy Grounding Design Standard [TEN-EL-ELGND-GLE Electrical Grounding Design Standard (CAN-US-MEX)] section 3.5.2 requires grounding of all conductive, non-current carrying equipment and materials in hazardous areas subject to static voltage buildup.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 4. General
    • (2) Without limiting the generality of subsection (1), the company shall ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the design, specifications, programs, manuals, procedures, measures and plans developed and implemented by the company in accordance with these Regulations.

Company action required:

The flammable liquid cabinets in the paint room shall be bonded to an earth ground.

Due date: 2020-02-11

Date closed: 2020-02-11
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 - CNC 2 - electrical grounding (Compressor Station 17)

Date & time of visit: 2020-02-12 11:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Electrical Safety
• Flammable and Combustible Liquids

Facility:

• STN 17 - REGINA [LINE 100-2] (Facility)

Observations:

CER staff observed flammable liquid safety cabinets in the paint room of Regina station that were not bonded to earth ground. 

TC Energy Grounding Design Standard [TEN-EL-ELGND-GLE Electrical Grounding Design Standard (CAN-US-MEX)] section 3.5.2 requires grounding of all conductive, non-current carrying equipment and materials in hazardous areas subject to static voltage buildup.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 4. General
    • (2) Without limiting the generality of subsection (1), the company shall ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the design, specifications, programs, manuals, procedures, measures and plans developed and implemented by the company in accordance with these Regulations.

Company action required:

The flammable liquid cabinets in the paint room shall be bonded to an earth ground.

Due date: 2020-02-13

Date closed: 2020-02-13
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:

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