Compliance Verification Activity Report: CV2122-381 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-381
Start date: 2022-02-22
End date: 2022-02-24

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

Verify response to INC2022-032 and 033. Verify company oversight on excavations, line skidding and other construction activities. Discuss and review high potential incidents on Spread 5A and verify field communication on incidents. Verify adherence to ground disturbance program and related prevention activities.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

There are no observations with outstanding follow-up

There are no observations with outstanding follow-up

Observation 1 - KP906- Bending

Date & time of visit: 2022-02-23 11:30

Discipline: Safety Management

Categories:

Facility:

Observations:

The contractor (SMJV) reviewed FLHA and site hazards. 

The inspection team observed pipe bending in progress. SMJV workers were positioning pipe on cribbing in preparation for equipment movement and pipe bending on the ROW. SMJV foreman and TM bending inspector reviewed the FLHA. CER IOs and IMs noted that all workers were observed wearing hearing protection as identified in the FLHA. 

Workers were using tag lines to control the load. One of the workers was observed to be within 1-2 feet from the edge of the pipe while holding onto the tag line. CER IOs and IMs noted that this method is not consistent with best practice as it may not prevent the worker from being struck by the pipe if it swung while being moved.  As tag lines were being used, worker could have positioned themselves out of the line of fire by increasing the tag line length. Trans Mountain to review and reinforce utilizing tag lines to control the load, while considering worker position to make sure they are not exposed to other hazards.
  
TMEP representative was not able to produce an equipment inspection log or checklist used for daily pre-use inspection as required per Trans Mountain’s HSMP, Rev 5, Section 48 for Pipe Bending Machine.

 
During the visitor orientation, the inspection team was informed that smoking was only allowed in designated locations. During the inspection at this location, a worker was observed smoking while assisting moving the pipe. No intervention was observed by the Company or contractor representatives to enforce the company policy. 

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Company action required:

TMEP representatives were not able to produce an equipment inspection log or checklist used for daily pre-use inspection as required per Trans Mountain’s HSMP, Rev 5, Section 48.

Ensure that affected workers are aware of and perform construction equipment inspection and are able to produce copies of such inspections when requested. Reinforce the use of equipment inspection log or checklists in line with manufacturer's requirements.   

During the visitor orientation, the inspection team was informed that smoking was only allowed in designated locations. During the inspection at this location, a worker was observed smoking while assisting moving the pipe. No intervention was observed by the Company or contractor representatives to enforce the company policy. 

Ensure that company's smoking policy is communicated to all workers and enforced as part of ongoing compliance activities. Submit communication of this policy to the workers. 

Due date: 2022-04-07

Date closed: 2022-04-11
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

There are no observations with outstanding follow-up

Observation 2 - KP 840.9- Steep slope

Date & time of visit: 2022-02-24 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

CER Inspection team arrive at this location and observed steep slope work in progress. A CAT 336F excavator was observed removing material from an excavation and placing it on a pile for loading by another excavator onto a rock/dump truck. CAT 336F excavator was anchored in line with the company's Steep Slope procedure. Work site appropriately identified as Steep Slope of greater than 21 degrees. Area foreman reviewed FLHA with the inspection team and reviewed the work in progress. 

Solid barricades were installed to prevent loose debris or rocks from rolling onto the adjacent public road. A chain link fence was in place to prevent public access to the work area. 

Area foreman and inspector were able to review the sloping requirements, and competency checks. An electronic version of the steep slope plan was available on site. 

As this work site was adjacent to a public road, good traffic management practices were observed. Two flaggers with radios were located on either side of the site. Sufficient area was available for dump/rock truck to back in for loading with the assistance of a spotter. 

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

Observation 3 - Incident follow-up

Discipline: Safety Management

Categories:

Facility: TRANS MOUNTAIN EXPANSION PROJECT - Pipeline

Observations:

CER Inspection team comprising of two CER Inspection Officers and two Indigenous Monitors (IMs) followed up on the status of INC2021-032 CER was informed that the injured worker was released from medical care and is now recovering.

The TMEP  incident investigation was still ongoing. SMJV has stopped all line skidding activities  on Spread 5A pending the outcome of the investigation. SMJV was assisting with performing the investigation. SMJV will be tracking corrective actions from this incident. CER was informed that bulletins on this incident were issued. CER was also informed that bulletins on INC2021-033 was also shared.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Relevant section(s):

Company action Required:

1. Provide copies of the safe work agreement on from Feb 15 to Feb 22 for Spread 5A to verify whether line skidding activities had occurred?

2.  Provide copies of bulletins or toolbox talks or other communication shared with the workers and management team on INC2021-032, and INC2021-033 incident on Spread 5A. 

3. Describe what actions, if any, TMEP takes following its incident follow-up to ensure that corrective actions have been properly identified and implemented.

4.  Provide any records of training and/or certification for workers involved line skidding. 

Due date: 2022-04-08

Observation 4 - Midday Valley Road Clearing (Coldwater re-route site)

Date & time of visit: 2022-02-23 10:40

Discipline: Safety Management

Categories:

Facility: TRANS MOUNTAIN EXPANSION PROJECT - Pipeline

Observations:

CER Inspection team arrived at the site where clearing and stripping was in progress at approximately the 6 km mark of the midday valley road.  Site Field Level Hazard Assessment (FLHA) was reviewed for clearing activities by SMJV clearing spotter. The inspection team was informed that no line skidding activities were occurring or anticipated at this location until the incident corrective actions have been implemented as required

While observing the clearing activities, a worker was seen crossing the forestry road multiple times. The location of the worker crossing was around a blind corner where vehicles coming downhill would be unlikely to stop in time. Although worker’s FLHA identified traffic control as needed, there was no visible warning for traffic to indicate that workers were present or crossing the road. This risk must be mitigated through company’s traffic management plan and submit steps taken to mitigate.

Compliance tool used: Notice of Non-compliance (NNC)

Regulatory requirement:

Relevant section(s):

Relevant section(s):

Company action Required:

1. Provide traffic management plan as applicable to forestry roads.

 

While observing the clearing activities, a worker was seen crossing the forestry road multiple times. The location of the worker crossing was around a blind corner where vehicles coming downhill would be unlikely to stop in time. Although worker’s FLHA identified traffic control as needed, there was no visible warning for traffic to indicate that workers were present or crossing the road.

Company to submit evidence that hazard due to vehicular traffic is adequately controlled at this location. 

Due date: 2022-04-07

Observation 5 - KP923 – welding

Discipline: Safety Management

Categories:

Facility: TRANS MOUNTAIN EXPANSION PROJECT - Pipeline

Observations:

The inspection team arrived at KP923 which is adjacent to a busy highway. Entrance to this ROW was not properly signed. TM representative informed the inspection team that a chain was placed across the site access to prevent entry. Additional signage warning of excavation and restricting access is needed to ensure that members of the public do not access this location when no workers are present.  
 
Pipe welding was in progress at this location in a welding shack equipped with general exhaust ventilation. Workers were observed to be wearing a PAPR and a half-mask respirator with P100 filters and a face shield when performing welding. Workers performing welding in this location were required to wear hearing protection. Workers adjacent to this work area were also observed wearing ear plugs or earmuffs, in line with the controls listed on the FLHA. 

The welding shack was held up by a boom truck and was centered on pipe. During the inspection, it was unclear if the whether shack should have been supported or secured by other means.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Relevant section(s):

Company action Required:

The welding shack was held up by a boom truck and was centered on pipe. During the inspection, it was unclear if the whether shack should have been supported or secured by other means. 

Provide manufacturer's instruction or procedure for installation and/or use of this style of welding shack (MWS1008- refer to attached image). 

1. Given the proximity to Highway 5a and the stop/ warning signage  present at other TMEP work sites along the ROW, please provide rationale for the signage at that site  that only read “Open Excavation” see picture #1 that was present during the inspection.

Due date: 2022-04-08