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

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2223-171
Start date: 2022-11-29
End date: 2022-12-01

Team:

Regulated company: NOVA Gas Transmission Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

Discipline(s):

Related events:

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:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Information Request

IR from CER (Information Request sent from CER to company)
#1. P/SSSP and SDS

Legislative Requirement : Canadian Energy Regulator Act (CERA)

Sections of the Act

  • Canadian Energy Regulator Act (CERA)
    • Administration and Enforcement
      • Duty to assist<br />103 (4) The owner or person in charge of the place and every person in the place must give all assistance that is reasonably required to enable the inspection officer to perform their duties and functions under this section and must provide any documents or information, and access to any data, that are reasonably required for that purpose.

Theme and Categories

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

Due Date : 2022-12-05

Review Response
Acceptable

Follow-up Action
None

IR from CER (Information Request sent from CER to company)
#2. Inspector duties and responsibilities

Legislative Requirement : Canadian Energy Regulator Act (CERA)

Sections of the Act

  • Canadian Energy Regulator Act (CERA)
    • Administration and Enforcement
      • Duty to assist<br />103 (4) The owner or person in charge of the place and every person in the place must give all assistance that is reasonably required to enable the inspection officer to perform their duties and functions under this section and must provide any documents or information, and access to any data, that are reasonably required for that purpose.

Theme and Categories

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

Due Date : 2022-12-05

Review Response
Acceptable

Follow-up Action
None

IR from CER (Information Request sent from CER to company)
IR #3, VAR- 001- IOO- DJM- 001- 2022 Response

Legislative Requirement : Canadian Energy Regulator Act (CERA)

Sections of the Act

  • Canadian Energy Regulator Act (CERA)
    • Administration and Enforcement
      • Duty to assist<br />103 (4) The owner or person in charge of the place and every person in the place must give all assistance that is reasonably required to enable the inspection officer to perform their duties and functions under this section and must provide any documents or information, and access to any data, that are reasonably required for that purpose.

Theme and Categories

Safety Management
  • Workplace Exposures and Protections
    • Occupational Medical Surveillance
    • Electrical Safety
    • Fire Protection
    • Flammable and Combustible Liquids
  • Training and Competency
    • Training, Competency and Qualification
  • Contractor Management & Oversight
    • Supervision, Inspection and Monitoring

Due Date : 2023-01-20

Review Response
Acceptable

Follow-up Action
None

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:

Facility:

Observations:

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

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:

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

HDD

Tie-in

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:

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).

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:

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:

Relevant section(s):

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:

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:

Relevant section(s):

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:

Facility:

Observations:

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