Compliance Verification Activity Report: CV2223-171 - NOVA Gas Transmission Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2927
• Inspector 2935

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Safety Management
• Indigenous Monitoring

Related events:

• CV2223-290
• CV2324-209

Rationale and scope:

Unannounced safety inspection of NGTL Groundbirch Mainline Loop Project (Sunrise section): The Project is located approximately 18 km northwest of Dawson Creek, British Columbia and consists of roughly 24 km of NPS 42. Verify implementation of the CSM and Kiskatinaw River HDD Execution Plan. Assess execution of work per applicable procedures and documented work practices.

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (1)
• Inspection Officer Order (IOO) (1)

Facility details

Facilities:

• GROUNDBIRCH MAINLINE LOOP (SUNRISE SECTION)

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)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Horizontal Directional Drilling (HDD) operations

Date & time of visit: 2022-11-29 09:30

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Fire Protection
• Flammable and Combustible Liquids
• Workplace Practices
• House Keeping
• Job/Task Safety Analysis
• Hazard Management
• Management of Hazardous Materials & Substances

Facility:

Observations:

Horizontal Directional Drilling (HDD) Rig 11 and Rig 5. 

• CER Inspection Officer (IO) received a site orientation, then inspected both HDD rigs
• Rig inspection group received a site orientation and reviewed the Field Level Hazard Assessment 
• IO observed workers managing powdered chemicals to be clean shaven, wearing correct respiratory protection and the Safety Data Sheets for the products in use were readily available
• Hearing protection required signage was posted on various buildings and noise survey information was also readily available
• No visible litter or refuse was found on site and waste materials were stowed in the correct bins
• The drill pit was cordoned off with fencing and signed, to prevent unauthorized access
• Whip checks were in use on hydraulic and other pressure hose connections
• Eye washes, first aid kits, and fire extinguishers were in place and showed signs of inspection
• Structurally, the IO could see no signs of advanced rust, corrosion, or faulty integrity
• The Rig's steam boiler was certified and had a daily inspection sheet, and the Rig Driller was the certified ticket holder
• Lifting and hoisting attachments and spreader bars showed signs of inspection and certification
• A variety of new lifting slings and chains were visible in the tool crib
• Flammable products were stored correctly in fire proof storage containers 
• Compressed gas bottles were stored outdoors and were segregated by product 

Compliance tool used: No compliance tool used

Observation 2 - Contractor Oversight - Safety

Date & time of visit: 2022-11-30 15:30

Discipline: Safety Management

Categories:

• Contractor Management & Oversight
• Responsibilities and Accountability
• Supervision, Inspection and Monitoring

Facility:

Observations:

Summary

CER Inspection Officers (IOs) and Indigenous Monitors (IMs) performed an unannounced safety inspection of the NGTL Groundbirch Mainline Loop Sunrise Section. Work scopes inspected included the Kiskatinaw River HDD crossing, sandblasting, coating, and welding/tie-ins.

The inspection results demonstrate that NGTL is inspecting construction work daily and is making efforts to ensure work is completed per the construction safety manual. Despite this, IOs observed deficiencies in NGTL's inspection of coating operations (see Inspection Officer Order VAR-001-DJM-001-2022). 

Field Observations

General

• NGTL Project Management Team (including Inspectors) and contractor representatives have daily morning meetings.
• The company has a dedicated safety lead for the project.
  • The safety lead performs and documents informal safety inspections of the contractor daily. Safety lead also aids NGTL Inspectors on safety matters.
  • Formal safety inspections are performed weekly. CER IO reviewed a weekly inspection performed on the HDD contractor. 
• CER IO reviewed records indicating the safety management plan for the project was approved by NGTL in June 2022. NGTL-approved copies of the GCC's P/SSSP and HDD Contractor's P/SSSP were available.

HDD

• An NGTL HDD Inspector (Inspector) is always present at the HDD site. Inspector duties are shared between a daytime and nighttime inspector (2 x 12 hours shifts).
• Inspector's duties include daily interaction with the contractor(s), including pre-shift safety meetings, daily walk-downs, and continuous monitoring of telemetry from the drilling rig.
• NGTL performs safety inspections of the HDD site that involve the HDD contractor, general construction contractor, NGTL safety lead, and NGTL HDD Inspector.
• IO reviewed a sample of the Inspector's daily reports, including safety observations.
• When asked by CER IO, the HDD Inspector demonstrated immediate access to the HDD Execution Plan but did not have access to the construction safety manual (Pipeline Execution Plan (PEP), SMP, and P/SSSP). See CNC 1.
• Inspector stated they participated in a full day of onboarding and training from NGTL before kickoff.
• Upon request from the CER IO, HDD roughneck demonstrated the ability to access the contractor's JSA's and SOP's.
• CER IO reviewed the boiler inspection certificate for rig 5 (HDD exit) dated 10 November 2022.

Tie-in

• CER IOs and IMs observed a tie-in (tie-in crew #2).
• CER IO spoke with the NGTL Welding Inspector (WI).
  • WI held CWB Level 2 certification
  • WI demonstrated access to the contractor's welding JSA, and he was familiar with the contents of the JSA.
  • WI confirmed he had the authority and responsibility to stop unsafe work.

Compliance tool used: No compliance tool used

Observation 3 - Communication between Projects (CER Incidents 2022-147 and 2022-149)

Date & time of visit: 2022-11-30 15:30

Discipline: Safety Management

Categories:

• Records & Documentation
• Internal near miss and incident trending, reporting, preventive and corrective actions

Facility:

Observations:

Through discussions with the NGTL Construction Manager, Safety Lead, and Welding Inspector, CER Inspection Officer is satisfied that NGTL has communicated the circumstances and initial lessons learned from two incidents that occurred on NGTL projects in August 2022 (CER Incident Numbers INC2022-147 and INC2022-149).

• CER IO asked NGTL Construction Manager (CM) how lessons learned are shared between NGTL projects. CM stated bi-weekly meetings are held with all CM's where lessons learned from incidents are shared. The CM knew about the two severe injuries on separate NGTL projects in August 2022 referenced above.
• NGTL Welding Inspector told IO that the project safety lead had informed him of the circumstances from INC2022-147 - an injury to a labourer on a tie-in crew on the NGTL Edson Mainline Loops project in August 2022.

Compliance tool used: No compliance tool used

Observation 4 - CNC 1 - Access to CSM

Date & time of visit: 2022-11-29 10:30

Discipline: Safety Management

Categories:

• Workplace Practices
• Duties and Responsibilities
• Procedures/Work Instructions

Facility:

Observations:

CER Inspection Officer requested a copy of the safety management plan and P/SSSP from NGTL's HDD Inspector. The document(s) were not immediately available.

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR) 2020-03-16

Relevant section(s):

• • 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:

Ensure the relevant parts of the construction safety manual are available at the HDD construction site.

Due date: 2022-11-29

Date closed: 2022-11-29
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 - Inspection Officer Order VAR-001-DJM-001-2022 - Coating

Date & time of visit: 2022-11-29 11:30

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Limits of Exposure
• Training and Competency
• Training, Competency and Qualification
• Contractor Management & Oversight
• Responsibilities and Accountability
• Supervision, Inspection and Monitoring
• Records & Documentation
• Occupational & Process Safety Information
• Hazard Management
• Management of Hazardous Materials & Substances
• General
• Signage

Facility:

Observations:

NNC -1 - Mainline coating operations 

1. Inspection Officers (IO) observed a mainline pipeline coating auto-spray operation, and reviewed an available Field Level Risk Assessment (FLRA) 
2. Two coating workers were observed exiting the spray shack, wearing disposable coveralls and full-face respirator,
3. The coating pump shack, which supports coating operations by facilitating transport of the coating pumping system, chemicals, hoses, and other support equipment including a compressor, generator and oil-field heater, was observed to be a mobile unit on a trailer, pulled by a tractor,
   • IO observed the pump shack did not have warning signs on it for applicable hazards that may be present inside the pump shack (chemicals, pressures, toxics, and fire and explosion hazards),
   • IO observed one way into and out of the pump shack via a fold down ladder,
4. A drum of Methyl Ethyl Ketone solvent (MEK) was observed unsealed inside the pump shack,
5. IO observed a blue parts bin inside the pump shack and was told a Technician was cleaning pump parts, MEK was decanted inside the blue bin, 
   • MEK solvent odour was noticeable from a distance,
   • Crew Foreman told the IO the support Technician was using MEK to clean pump parts, but had been "using a half-face filter respirator",
     • IO observed the support Technician using MEK had a long beard and was not clean shaven to meet the requirements of a Fit-Test or respiratory protective equipment (RPE) program, per CSA Z94.4:18 Selection, care and use of respirators. 
6. Other than the main entry door, the pump shack was observed to not have any open ventilation ports, exhaust type fan systems, or explosion relief blast hatches,
7. The pump shack and individual workers did not have a means to detect or monitor for potential toxic exposures, or explosive hazards inside the pump shack, using fixed or personal monitor systems, 
8. Non-intrinsic household style,120v portable heaters were observed inside the pump shack and plugged in to non-intrinsic power bars, running off extension cords - the heaters were heating the shack and consequently the drum of MEK,
   • IO requested workers to unplug the non-intrinsic heaters for safety reasons, workers unplugged the heaters, 
9. The IO did not observe and could not verify a method of bonding or grounding of chemical containers, or that static electricity charges were under control while transporting, handling, usage and storage of an open drum of MEK, 
10. IO observed diesel powered, flame fired, oil field heaters on the shack trailer, just behind the pump shack,
11. IO was able to obtain a readily available copy of the Safety Data Sheet (SDS) for MEK, from the Crew Foreman who had the SDS available on an Ipad,  
    • IO noted eight to ten safety controls listed in the SDS for transporting, handling, using and storing MEK, were not in place while coating operations were underway,
12. The spray shack tent, as a suspended load being hoisted by a side-boom crane, had a certified lifting device (spreader bar) with attached components (the coating sprayer) shackled and supported by the spray shacks main structural beam inside the tent, as part of a lifting operation; however, the beam nor components displayed an engineers certification or identification of the safe working load limit (WLL). While the spreader bar displayed a safe working load limit, the equipment it was supported by did not.

Compliance tool used: Inspection Officer Order (IOO)

Regulatory requirement:

• Canadian Energy Regulator Act (CERA)

Relevant section(s):

• • General Duty
    • Reasonable care
      94 The holder must take all reasonable care to ensure the safety and security of persons, the safety and security of regulated facilities and abandoned facilities and the protection of property and the environment.

Company action required:

Specified Measures and Corrective Actions. 
1.   Cease the use of the pipeline spray-coating application system, provided by CRC- Evans, until a method of competent construction inspection, through the utilization of training, knowledge, and expertise, of the components, the use, and operation of the coating system, can be demonstrated to the Inspection Officer.

  Specified Measures and Corrective Actions 
2.   Provide assurance that those assigned the responsibility of General, Safety or Coating inspection, on behalf of NGTL, can demonstrate compliance with WHMIS requirements (as required by Condition 2 of Order XG-029-2019 and the Construction Safety Manual).
  Specified Measures and Corrective Actions 
3.   Provide to the Inspection Officer for review, an assessment completed by NGTL to identify the regulatory and legal requirements to safely manage Methyl Ethyl Ketone liquid, in line with Canada Energy Regulator Onshore Pipeline Regulations 6.5(1)(g) and 6.5(1)(h); and explain which requirements apply, and how they are implemented within the NGTL Management System.
  Specified Measures and Corrective Actions
4.   Demonstrate that NGTL has reviewed the applicability of Management of Change (MOC), or a Hazard Analysis, of the CRC-Evans spray coating system, and provide to the Inspection Officer for review a summary of the key safety hazards and the management controls for MEK and other pipeline coating chemicals.
  Specified Measures and Corrective Actions
5.   Provide a Corrective and Preventative Action Plan, noting systemic actions that will prevent recurrence, and detailing time to completion of Specified Measures 2, 3, & 4, to the Inspection Officer for review. Specified Measures and Corrective Actions 
6. With regard to the details noted in this Observation, review and provide information related to items #3 - #12, and what if any measures have been taken.  Specified Measures and Corrective Actions.
7. Provide a copy of the latest version, of an NGTL Coating Inspector's required training, time of minimum practice and experience, inclusive to job roles and responsibilities. 
 

Due date: 2023-01-13

Date closed: 2023-02-17
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 6 - IM Observations - Lac Ste. Anne Métis Community Association

Date & time of visit: 2022-12-15 12:00

Discipline: Indigenous Monitoring

Categories:

• General
• General

Facility:

• GROUNDBIRCH MAINLINE LOOP (SUNRISE SECTION) (Pipeline)

Observations:

• Discussion between IO, IM and NGTL drilling contractor representative was about no hoodies up underneath hard hat, (NGTL safety policy). The next day at the coating crew I observed a worker with his hoodie up under his hardhat and pointed that worker out to the IO, who in turn asked the NGTL rep what the policy was. The representative replied that it was cold out and that NGTL was working on changing their policy on this matter. The IO said he would look further into this matter.

• In conversation with the company environmental inspector about the mitigation for the archaeological site along the edge of the drill path, he mentioned that there was snow fence around the site with signage in place.

• IM and I reviewed and discussed the frack out location with the company environmental inspector, including the triple barrier around the location with frozen- in sections of plastic culvert to contain and make it easier for the vac truck to extract the drilling fluid. He also mentioned that the frack location was on private property.

• Rope lighting from rig to edge of riverbank along drill path at both the entry and exit rig locations, NGTL environmental inspector explained not a lot of light this time of year and this works well for frack walks at low or no light.

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: