Compliance Verification Activity Report: CV2223-140 - TransCanada Keystone Pipeline GP Ltd.

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 2927

Regulated company: TransCanada Keystone Pipeline GP Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• Alberta

Discipline(s):

• Safety Management

Rationale and scope:

Safety field inspection of O&M activities at the Lakesend Pump Station.

Compliance tool(s) used:

• Notice of Non-compliance (NNC) (1)
• Assurance of Voluntary Compliance (AVC) (1)

Facility details

Facilities:

• LAKESEND EAST PS

Facility Types

• Pipeline
• Pipeline
• Pump station

Life-cycle Phases

• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2021-07-01
• Canada Labour Code (CLC) 2021-12-29
• Canadian Energy Regulator Act (CERA)
• Canadian Energy Regulator Act (CERA)
• Onshore Pipeline Regulations (OPR) 2020-03-16
• Canadian Energy Regulator Pipeline Damage Prevention Regulations – Obligations of Pipeline Companies
• Plans And Procedures
• Standard Operating Procedure or Plan (SOP)
• TC Energy Lockout and Tagout Procedure (CAN-US-MEX) Rev. 09
• Standard Operating Procedure or Plan (SOP)
• TC Energy Operating Procedure: Pressure Safety Valve Inspection Canada Rev. 03
• Standards
• CSA Z662-19 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - NNC 1 - Lakesend P/S 6 PSV Replacement

Date & time of visit: 2022-10-05 10:00

Discipline: Safety Management

Categories:

• Hazard Management
• Management of Hazardous Energy

Facility:

Observations:

CER Inspection Officers (IOs) reviewed a Lockout and Tagout Energy Isolation Plan and Equipment Specific Instruction Form (isolation plan) for a PSV replacement at the Lakesend pump station.

The isolation plan listed three electrical and two mechanical isolation points, including:

1. LKSND-AO-CSO-0301A upstream CSO valve, located at the inlet of the PSV injection skid.
2. LKSND-AO-CSO-0301B downstream CSO valve, located at the outlet of the PSV injection skid.

When IOs walked down the work area, they observed locks on the two valves listed above. They noted that there appeared to be no mechanical isolation between the station suction piping and the PSV other than a check valve and the injection pump.

Company representatives, including authorized workers who had signed onto the isolation plan, agreed that workers needed an additional mechanical isolation point before starting the work. The isolation coordinator created a new isolation plan and applied an additional lock on LKSND-AO-CSO-0303.

The original isolation plan, however, appeared to have been completed with all locks applied and signed by the isolation coordinator, reviewer, authorized workers, and affected workers. Checkboxes were marked complete indicating TC Energy had verified the isolation plan for accuracy via a walkthrough of the workplace and a review of drawings. 

The methods to verify the original isolation plan's accuracy appeared to be  ineffective in identifying a missing mechanical isolation point. 

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

Regulatory requirement:

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

Relevant section(s):

• • 6.5
    • (1) A company shall, as part of its management system and the programs referred to in section 55,
      • (f) establish and implement a process for developing and implementing controls to prevent, manage and mitigate the identified hazards, potential hazards and risks and for communicating those controls to anyone who is exposed to the risks;

Company action required:

1. State if TC Energy completed the original isolation plan per the company's energy isolation requirements in isolating the PSV (check valve, closed drain valve, and pump between the work area and mainline pressure).
2. If not, identify the factors or causes why the original walkthrough, review of drawings, and sign-off by the isolation coordinator and reviewer failed to identify the missed isolation point TC Energy added to the revised isolation plan.
3. Describe the actions TC Energy will take to address the factors of causes identified in #2.

Due date: 2022-11-11

Date closed: 2022-02-16
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 - General Observation - Safety

Date & time of visit: 2022-10-05 08:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Workplace Practices
• Hot Work
• Safe Work Permits
• House Keeping
• Job/Task Safety Analysis
• Procedures/Work Instructions
• Hazard Management
• Management of Hazardous Energy

Facility:

• LAKESEND EAST PS (Facility)

Observations:

• CER visited Lakesend Pump Station to observe annual maintenance activities being performed. The activities occurring while CER staff were on site were the replacement of two Pressure Safety Valves(PSV). 
• CER participated in the pre-job review of the JSA and site-specific orientation, which included the muster points and locations of the ESDs.
• The facility was equipped with a wind sock. In addition, survey ribbon was tied at both locations where the PSVs were being replaced as an added indicator due to the wind direction changes close to the risers. 
• The authorized workers conducting the PSV replacement wore SCBA and personal gas monitors. CER Inspection Officers (IOs) were told that the gas monitors had been bump tested that morning and that each worker conducted their own pre-use inspection of the SCBA. IOs were told that workers are assigned their own masks for use with the SCBA. 
• PSV LOTO:
  • The Company walked the CER through the job process, which started in the Motor Control Panel room where the 'isolation coordinator' and 'authorized workers' reviewed the 'Isolation Plan' and the electrical components of AO-PM-02 and AO-PM-01 were locked and tagged out. They were then walked through the isolation points on the pumps in the yard where the PSVs were to be changed.
  • During the walk-through of the 'isolation plan' a third energy source and isolation point was not reflected in the original plan (see NNC 1).
  • IOs were told that the PSV replacement is an annual task and that the TCE engineering department had created a new pre-populated isolation plan for this task and that as a result of the field changes the PSV replacement isolation plan would be put through the appropriate TCE management of change procedure to be updated. 
• Labelling:
  • During the walk-through, the CER noted that on/off switches located at the sump related to pump AO-PM-01 and AO-PM-02 were not labelled to identify their function. The CER was told that workers had local knowledge of its function. 
  • AO-PM-02 and AO-PM-01 pumps did not have identification labels.
  • This is a repeat finding with respect to the labelling of equipment on the TCE system - Inspection Officer Order TH-001-2019 see (AVC 1).
• The CER observed that the overall site was well maintained.
• The station is accessible year-round, and its design and fencing prevent unauthorized entry. The station is equipped with sufficient emergency exit gates and the main gate. 
• Signage was present at the main gate and fencing with the appropriate information as required by CSA Z662 for facilities. 
• All piping within the facility was marked with the direction of flow. 
• Portable fire extinguishers and spill kits were available throughout the station.
• The cold storage building was well-lit, with good housekeeping.
• The flammables storage cabinet housed in the cold storage only contained approved items and had its bungs in place.  
• CER noted that all cranes were labelled with their weight limit and valid inspection labels were on each crane. The CER noted that the chain hoist on site matched the load rating on the cranes. 

Compliance tool used: No compliance tool used

There are no observations with outstanding follow-up

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to:

Observation 3 - 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