Compliance Verification Activity Report: CV1920-486 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-486
Start date: 2019-12-18
End date: 2019-12-20

Team:

Regulated company: NOVA Gas Transmission Ltd.

Operating company: NOVA Gas Transmission Ltd.

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

Operational inspection to verify compliance with the OPR, CLC and company-specific requirements. Included compressor stations along the Edson Mainline. Focus areas included the following areas: hazard and risk identification - Arc Flash - IOGP Life Saving Rules (Bypassing Safety Controls, Confined Space, Driving, Energy Isolation, Hot Work, Line of Fire, Safe Mechanical Lifting, Work Authorization and Working at Heights)

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2019-12-18 08:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 2 - Observations: Schrader Creek

Date & time of visit: 2019-12-18 08:30

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 3 - Observations - Wolf Lake Compressor Construction

Date & time of visit: 2019-12-20 09:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

There are no observations with outstanding follow-up

Observation 4 - NNC 1: Positive Air Shut Off Failure

Date & time of visit: 2019-12-20 09:30

Discipline: Safety Management

Categories:

Facility:

Observations:

It was observed in a restricted area that a light standard powered by diesel fuel had a non-functioning PASO system.

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

Regulatory requirement:

Relevant section(s):

Company action required:

The following preventive actions are recommended:
• utilize the hierarchy of controls in determining positive shutoff equipment requirements;
• ensure the procedures address the method for confirming the functionality of positive air shutoff equipment;
• ensure responsible persons are adequately trained; and
• conduct inspections, testing and maintenance pursuant to the schedule outlined in procedures or according to manufacturer’s specifications.
 

Due date: 2020-05-05

Date closed: 2020-05-13
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

Observation 5 - NNC 2: Oversight of Industrial Radiography Contractors

Date & time of visit: 2019-12-20 10:00

Discipline: Safety Management

Categories:

Facility:

Observations:

The CER inspector has assesed the TC energy response to a IR to provide records demostrating adequate oversight of industrial radiography contractors as inadequate. TC energy has provided no evidence of the oversight of work being conducted by Radiography contractors with respect to their personal health and safety. TC energy has provided evidence of contractor selection criteria and pre-qualification however this demonstartion falls short of what is required in the opinion of the CER inspector.

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

Regulatory requirement:

Relevant section(s):

Company action required:

Confirm to CER inspectors what actions will be taken to demonstrate adequate contractor oversight of NDT activities with respect to contractor health and safety.

Due date: 2020-09-10

Date closed: 2020-09-10
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 6 - Information Request: NGTL (TC Energy) Incident Investigation Process

Date & time of visit: 2020-02-04 13:30

Discipline: Safety Management

Categories:

Facility:

Observations:

NGTL (TC Energy) were unable to produce an incident investigation report for the Severed Cable incident that occurred during concrete cutting at Schrader Compressor Station.

Compliance tool used: Information Request (IR)

Regulatory requirement:

Relevant section(s):

Company action required:

Please provide CER inspector with a copy of the NGTL (TC Energy) Incident Investigation Procedure. Please provide an explanation of NGTL (TC Energy) expectation of contrators with respect to investigation of their own incidents.

Due date: 2020-02-28

Date closed: 2020-05-13
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

Observation 7 - NNC 3: Failure to Investigate

Date & time of visit: 2019-12-18 10:00

Discipline: Safety Management

Categories:

Facility:

Observations:

NGTL (TC Energy) were unable to produce an investigation report into an incident that occured at Schrader Compressor Station where a 120V electrical cable was damaged during concrete cutting operations. There was a failure to classify and investigate the incident as per TC Energy's Incident, Quality and Compliance Classification Guide and Incident Investigation Process.

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

Regulatory requirement:

Relevant section(s):

Company action required:

Complete and submit an investigation as per TC Energy's internal process. Include systemic causes with consideration given to contractor oversight.

Due date: 2020-07-08

Date closed: 2020-07-10
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:

- 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 8 - 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