Compliance verification activity type: Field Inspection
Team:
Regulated company: TransCanada Keystone Pipeline GP Ltd.
Operating company: TransCanada PipeLines Limited
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Safety field inspection of O&M activities at the Lakesend Pump Station.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - NNC 1 - Lakesend P/S 6 PSV Replacement
Date & time of visit: 2022-10-05 10:00
Discipline: Safety Management
Categories:
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:
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:
Relevant section(s):
Company action required:
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
Compliance tool used: No compliance tool used
There are no observations with outstanding follow-up
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 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