Compliance Verification Activity Report: CV2122-302 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Activity #: CV2122-302
Start date: 2021-09-13
End date: 2021-09-17

Team:

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

Discipline(s):

Related events:

Rationale and scope:

TMX Burnaby & Westridge Terminal including tunnel boring activities. Verify effective implementation of construction safety manual and project specific safety plans including contractor oversight, implementation and oversight of the commitments made in condition 26 filing(s). Verify corrective actions from high potential near miss (incident 963, 14 Apr 2021) have been implemented on barges.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - Day 1 (Sept 14)- General Observations- Westridge Marine Terminal

Date & time of visit: 2021-09-14 07:30

Discipline: Safety Management

Categories:

Facility:

Observations:

Tunnel Boring Machine

  1. Reviewed Daily Execution Plan, and Pre-Task meeting documentation performed by the McNally crew working near the Tunnel Boring Machine (TBM). Daily Execution Plan had identified silica dust as the topic of discussion. As the TBM was shut down during the inspection, no observation or verification were made on operational aspects of the TBM.
  2. HS 855 crane was present on site, however, was not operating during the inspection. An excavator was also observed to be operating in the area. A risk board (also known as a sandwich board) was located at the site entry to TBM portal.
  3. Signage was available for hearing protection and silica dust, however, these were not installed during the inspection as the equipment was not operating. McNally reported that a hygiene consultant company had performed airborne silica measurements. 
  4. Crew FLHA was reviewed for removal of tunnel half rings, false rings  and general site clean up near the tunnel portal.
  5. Two workers were observed to be cutting bolts used to support the TBM outside the tunnel. Workers were using an acetylene torch  to cut the bolts. Workers had erected a welding screen for spark containment. As the worker performed bolt cutting, spark containment was observed to be inadequate. McNally worker was asked to erect another screen to better contain the sparks. Workers placed another screen in the area.
  6. CER IO reviewed a high-voltage lockout process with an assigned Electrician.
    1. Electrician was able to speak to the TBM power cable and tether isolation process
    2. Electrician was able to demonstrate knowledge and use of ARC flash protection PPE
    3. CER IO observed there to be lockout tags on isolation points, tags were complete noting who locked out the equipment and how to contact that person
  7. CER IO reviewed the McNally Contractor's work shack and was able to readily acquire safety related documentation including a construction safety manual.
    1. CER IO notes McNally recently completed a man-down rescue and response drill for in-tunnel emergency response with newly trained rescue and response personnel. 
Covid-19 Measures
  1. CER IO observed many workers using and applying Covid-19 prevention face masks when within two meters of other workers and when indoors.
  2. Hand washing and hand sanitizer stations were readily available across the site along with correctly marked garbage and waste bins.

Permit to Work 
  1. CER IOs performed an engagement with WMT operators located in the operations building. A discussion on operations oversight of the safe work permit was carried out. Permits for September 14, 2021 were reviewed to understand the permitting system in place. Operations clarified that any brownfield permits are in care and control of Operations. Green field permits issued to TMEP are reviewed by the operators and signed to the extent of an acknowledgement that a given work scope is being performed in the green field. Operators stated that there is no ownership or custody by Operations of the work being performed in the green field. TMEP is responsible for managing risks in the green field.
  2. Further discussion with Operations on communication of risk or activities revealed that TMEP informs Operations on daily risks either through the permit process or through the safety flash/messaging system. Operations coordinates shut down or adjustment to their work fronts where TMEP work impacts Operations activities.
General Construction
  1. Box culvert demolition work was also reviewed. The risk board showed that workers had identified asbestos (transite board) as a hazard during the demolition. During the inspection, work in this area was shut down and awaiting an abatement crew to assist with removal of asbestos. Area supervisor reviewed the DEP and FLHA.    
  2. Observed Keller workers near grout tanks. Interview with the Keller supervisor revealed that grout product contains crystalline silica which was identified as a hazard on Keller FLHA. Use of hearing protection was also noted in the Keller FLHA.
  3. As troubleshooting was being performed on the grout tanks, most workers were observed without any hearing protection. One worker on the top deck of the operating secondary separation unit (SSU) was seen to be working without hearing protection. IO engaged the area supervisor and worker was provided with hearing protection. Importance of donning hearing protection was reviewed with the area supervisor. (See CNC -2)
  4. CER IO observed a rental trench box on-site (photos attached). Aided by a site Civil Foreman, IO reviewed a pre-use Inspection form, and visually assessed the trench box using the inspection form, noting applicable retaining pins and keepers were in place as per the inspection form.

Compliance tool used: No compliance tool used

Observation 2 - Day 2 (Sept 15)- General Observations- Burnaby Terminal

Date & time of visit: 2021-09-15 07:30

Discipline: Safety Management

Categories:

Facility:

Observations:

Opening Meeting and Orientation 

Site Tour Pipe Sand-Blasting and Coating

Compliance tool used: No compliance tool used

Observation 3 - Day 3 (Sept 16)- General Observations- Burnaby Terminal

Date & time of visit: 2021-09-16 06:00

Discipline: Safety Management

Categories:

Facility:

Observations:

  1. IOs participated in TMEP Safety Inspector and craft inspector meetings.
  2. IOs participated in morning pre-task meeting or toolbox talk with the pipefitter, millwright and ironworker crew. IOs observed how TMEP safety talk of the day is discussed in the field. Observed pre-work stretches performed by the crew.
  3. IOs engaged a welder apprentice during the completion of the FLHA. Apprentice explained the process of completing the FLHA and sign off process.
  4. IOs engaged the carpenter crew near manifold area. FLHA was reviewed and discussion on hazards of the day. Crew’s sling storage was inspected. Wire slings were stored with appropriate tags. Worker confirmed that pre-use inspections are performed.
    1. IO observed there to be a damaged or faulty sling in the sling storage box, the contractors rep immediately took the sling out of service
  5. IOs participated in TMEP and KLTP management safety walk down. This is a new initiative at Burnaby terminal site.
    1. IOs observed the TMEP Inspector engage with Civil Construction Crews about steep slopes and heavy equipment interface.

Compliance tool used: No compliance tool used

Observation 4 - CNC - 1 - Covid-19 Prevention and Protection

Date & time of visit: 2021-09-15 07:30

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Update the site specific visitor orientation to reflect current BC Ministry of Health public health orders. 

Due date: 2021-09-23

Date closed: 2021-09-20
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 - NNC - 1 - Compressed Breathing Air System and certification of Breathing Air Quality

Date & time of visit: 2021-09-15 10:01

Discipline: Safety Management

Categories:

Facility:

Observations:

Notice Non-Compliance (NNC) - 1

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

Regulatory requirement:

Relevant section(s):

Company action required:

Provide to the Inspection Officer for review, a corrective action plan to address the Non-Compliance for compressed breathing air systems, worker fit-test programs, and equipment inspections. 

Due date: 2021-09-17

Date closed: 2021-09-17
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 - CNC - 2 - Hearing Protection PPE

Date & time of visit: 2021-09-14 11:45

Discipline: Safety Management

Categories:

Facility:

Observations:

CNC - 2 - Hearing Protection 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Ensure all workers exposed to levels of noise at the work site are abiding by the posted signage and requirements to use hearing protection.

Due date: 2021-09-14

Date closed: 2021-09-15
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

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