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


Compliance verification activity type: Field Inspection

Activity #: CV2223-140
Start date: 2022-10-05
End date: 2022-10-05


Regulated company: TransCanada Keystone Pipeline GP Ltd.

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):


Rationale and scope:

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

Compliance tool(s) used:

Facility details


Regulatory requirements

Regulatory requirements that apply to this activity:

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




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:

Relevant section(s):

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




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:

- 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