Compliance Verification Activity Report: CV2021-220 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2927
• Inspector 1137

Regulated company: Trans Mountain Pipeline ULC

Operating company: Kinder Morgan Canada Inc

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Safety Management
• Indigenous Monitoring

Rationale and scope:

Spread 5a - TMX Project Construction Inspection; 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:

• Information Request (IR) (1)
• Notice of Non-compliance (NNC) (1)

Facility details

Facilities:

• TRANS MOUNTAIN EXPANSION PROJECT

Facility Types

• Pipeline
• Pipeline

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• 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
• Trans Mountain Expansion Project Health and Safety Management Plan, TMEP Document # 01-13283-GG-0000-HS-PLN-0001 R4
• Project-specific plan or procedure
• Welding Cutting Grinding Job Safety Analysis, TMEP-HS-JSA-048 Rev 0
• Project-specific plan or procedure
• Pipe Support & Skidding Operations Standard, SMJV Document # SMJV-OP-STN-009 Rev 0
• Project-specific Contractor/Project Safety Plan (CSP)
• Trans Mountain Expansion Project, PSSP Spread 5A, TMEP Document # Document # 01-13283-S5A-0000-HS-PLN-0001 R5

Observations (no outstanding follow-up required)

Observation 1 - IR 1 - document request

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Hazard Assessment

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

Documents are requested for the purpose of verfiying that field observations meet the criteria of written standards.
 

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.
    • (2) A company shall keep a copy of the construction safety manual or the relevant parts of it at each construction site of the pipeline, in a location where it is accessible to every person engaged in construction at the site.

Company action required:

Provide a copy of the following documents:

1. SSMJV-HS-TMP-049, Welding Cutting Grinding JSA, latest revision
2. Cribbing/Skidding Plan that applies to Spread 5.

Due date: 2020-11-27

Date closed: 2020-11-25
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 2 - Covid-19

Date & time of visit: 2020-11-18 08:30

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Industrial Sanitation and Personnel Facilities
• Hazard Assessment

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• TMX self-declaration Rev. 6 forms were completed by all members of the inspection team prior to entering the worksite.
• Daily temperature screening was performed on all members of the inspection team.
• Hand sanitizer was available throughout the office trailers at the construction yard.
• Workers were observed maintaining physical distance of 2 meters from each person. Masks were worn by workers when working within 2 meters of another person.
• CER inspectors observed documented checklists demonstrating the office trailers and common indoor spaces were cleaned at 2-hr intervals in accordance with the Covid-19 Response Plan.
• TMEP Covid-19 Response Plan was observed posted in a conspicuous location in the safety trailer.

Compliance tool used: No compliance tool used

Observation 3 - Airport - (kp 840+500)

Date & time of visit: 2020-11-18 13:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Hazard Assessment
• Permanent Structures
• Housekeeping
• Signage
• Training and Competency
• Training, Competency and Qualification

Facility:

Observations:

• CER IOs reviewed a field level hazard assessment prior to accessing the worksite.
• Traffic was managed with markers, road signs, and flaggers.
• CER IOs observed a trench box inside an excavation that had been ribboned off and not used since 2 Nov 2020 due to the directive from Trans Mountain to all Contractors on the project to stop using, assembling, and disassembling trench boxes.
• Bathrooms and hand sanitizer were available at the worksite.
• CER IOs observed a welding crew removing corks from an excavator track:
  • workers were observed wearing appropriate PPE including double eye protection
  • no flammable or combustible materials were observed in the immediate vicinity of the hot work.
  • a fire extinguisher was readily available
  • hand held grinders had guards in place
  • a documented field level risk assessment was available for review
  • when asked, workers were aware of the emergency response plan (ERP), and how to summon help in the event of an emergency.
  • CER IO asked a welder how he ensured the grinding disc being used was appropriate for the grinder. The welder was unaware of the maximum rotational speed of his hand held grinder (believing the maximum speed to be 6000rpm instead of 9000rpm), and was also unaware the maximum speed was stamped on the tool itself.
  • although the disc on the tool was rated for 10,200rpm, it raised concerns about how workers ensured discs were appropriate for the tool being used. This concern was immediately addressed and followed up by both the welder and company safety representatives. 
  • upon further inquiry, company representative stated that all discs for hand held grinders were distributed by SMJV thereby assuring appropriately rated discs were used.
• IOs observed workers wearing PPE in accordance with the PSSP.
• IOs observed that workers tasked with offloading pipe from a trailer 1) planned their work, 2) discussed hazards, and 3) remained out of the line of fire when performing the work.
• IOs observed stringing operations with the use of a Deckhand Pipe Handling System.
• On 19 Nov 2020 CER IO observed that temporary pipe supports used while stringing did not meet the requirements of the Trans Mountain Contractor Safety Manual, or the requirements of the SMJV Pipe Support & Skidding Operations Standard (see NNC 1).

Compliance tool used: No compliance tool used

Observation 4 - Thompson River HDD

Date & time of visit: 2020-11-19 09:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Ropes, Chains and Slings
• Permanent Structures
• Housekeeping
• Shelving and General Storage
• Signage

Facility:

Observations:

• No drilling activity was taking place at the time of inspection.
• CER IOs observed that access to the HDD entry on the south side of the Thompson River was restricted with a gate and a security guard.
• A site specific orientation was performed before touring the work site.
• Access mats covered the entire footprint of the work site.
• IOs observed good housekeeping practices.
• Slings used for rigging were organized and appeared to be in good condition.
• Washrooms equipped with hand sanitizer were readily available.
• Compressed gas cylinders were secured in the upright position with safety caps in place.
• Propane bottles were stored outside.
• Equipment such as light plants and pumps appeared to be electrically grounded.
• Two unopened and sealed barrels of oil (EP220 and Oil 320) were observed in the tool trailer without secondary containment. IO questioned the company as to whether secondary containment was required. The company indicated the matter had already been addressed in a previous CER environmental inspection.

Compliance tool used: No compliance tool used

Observation 5 - NNC 1 - Pipe Support and Skidding

Date & time of visit: 2020-11-19 14:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Hazard Assessment
• Training and Competency
• Training, Competency and Qualification

Facility:

Observations:

• On 19 Nov 2020 CER IO observed stringing operations south of Airport Road in Kamloops, BC.
• Several sections of welded pipe were observed that were supported by skids.
  • One section of pipe was not supported with a chock or crotch at each lose end as required by section 5.2 of the SMJV Pipe Support & Skidding Operations Standard (contractor standard). This configuration also does not meet the requirements of section 8.2.10 of the Trans Mountain Contractor Safety Manual found within the Trans Mountain Health and Safety Managemnt Plan (HSMP).
• IO observed workers constructing skid piles for a  section of pipe that was vertically supported by side-booms. Although the skid and crotch configuration met the requirements of the contractor standard, the placement of crotched skids did not meet the requirements of the HSMP. Specifically, crutching was not placed on the 1st cribbing from the loose end.
• The written requirements for skidding found within the contractor standard do not meet all of the requirements of the HSMP with respect to the placement and options for crutching and chocks.

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

Regulatory requirement:

• Project-specific plan or procedure
• Trans Mountain Expansion Project Health and Safety Management Plan, TMEP Document # 01-13283-GG-0000-HS-PLN-0001 R4

Relevant section(s):

• Where welded sections of pipe joints are strung, crutching shall be installed on the 1st. 3rd and 5th cribbing from any loose end and every 5th set of cribbing thereafter

Company action required:

1. Provide evidence that the Contractor Cribbing/Skidding Plan (plan) meets the requirements of Trans Mountain Expansion Project Health and Safety Management Plan, TMEP Document # 01-13283-GG-0000-HS-PLN-0001 R4.
2. Provide confirmation that all workers tasked with performing or overseeing cribbing and skidding work on this spread have been trained on the requirements of the plan.

Due date: 2020-12-24

Date closed: 2020-12-24
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: