Compliance Verification Activity Report: CV1920-510 - Trans-Northern Pipelines Inc.

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1920-510
Start date: 2020-02-18
End date: 2020-02-19

Team:

Regulated company: Trans-Northern Pipelines Inc.

Operating company: Trans-Northern Pipelines Inc.

Province(s) / Territory(s):

Discipline(s):

Rationale and scope:

This inspection will focus on the activities occurring related to the TNPI Integrity Dig on Harcourt Crescent.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Observations (no outstanding follow-up required)

Observation 1 - General Damage Prevention

Date & time of visit: 2020-02-19 13:00

Discipline: Damage Prevention

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 2 - General Safety

Date & time of visit: 2020-02-19 13:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Compliance tool used: No compliance tool used

Observation 3 - NNC - Engineering Dig Sheet

Date & time of visit: 2020-02-19 13:00

Discipline: Safety Management

Categories:

Facility:

Observations:

Prior to the inspection TNPI provided the CER with the safe excavation pressure along with the an explanation of how this pressure was derived. While onsite the TNPI field representative showed the Inspection Officer (IO) an electronic version of an XL spreadsheet which contained the safe excavation pressure. This information was communicated to the crew and during the morning toolbox meeting and was consistent with what had been provided to the CER prior to arriving onsite.
 
While reviewing the onsite field Dig Package, the IO noted that an engineering dig sheet for this location contained a predicted burst pressure in kPa that differed significantly from the predicted burst pressure in Psi previously provided to the CER in its explanation of how the safe excavation pressure was derived. Once the IO noted the discrepancy between the two values it was brought to the attention of TNPI field representatives, who at the time, believed this to be a typographical error. Work was temporarily suspended to ensure the safety of the workers and the public. TNPI field representatives proceeded to investigate. After consultation with TNPI engineering department, TNPI field representatives told the IO that the engineering dig sheet was generated in 2018 and should not be in the Dig Package, and that the safe excavation pressure provided to the field representatives in the electronic XL spread sheet was accurate; work was resumed.
During post inspection communication, the IO was told that the predicted burst pressure on the engineering dig sheet was not a typographical error and that it was accurate in 2018, however, it was no longer current. The IO was also told that TNPI changed its practice in 2019 to no longer record the predicted burst pressure on the dig sheet as this was not required information for field representatives, only the safe excavation pressure is required information. TNPI told the IO that the amended procedure was “communicated to all digs crews thru training in November 2019”.  
 
The OPR requires that TNPI have processes in place for the effective communication of information; reviewing and revising of documents; maintaining records; and for coordinating and controlling operational activities to so that each person has the information that will enable them to perform their duties in a manner that is safe, ensures the security of the pipeline and protects the environment. The IO is of the view that while the predicted burst pressure was not a typographical error, it was not current and its presence and different unit of measurement in the onsite field Dig Package without notation or red line caused confusion. In addition, the IO is of the view that gaps exist in the effectiveness of the training and communication of this information given the number of TNPI and contractor representatives involved and the amount of time it took to determine that this information should not have been in the onsite field Dig Package.
  
As a result of the observations, the IO determined that TNPI failed to ensure the implementation and effectiveness of its procedures. This failure is potentially related to several elements of the safety program and the management system including: OPR 6.5.(1)(m)(o)(p), 6.5(2) and CSA Z662 10.4.1
 

 

 




 

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

Regulatory requirement:

Relevant section(s):

Company action required:

Based on the observations noted and in order to prevent a similar gaps in the Quality Assurance/Quality Control (QAQC) of its communication and procedures, the IO is requiring that TNPI conduct a review of this event and develop a plan to correct similar gaps for its Integrity digs. The plan must also include measures TNPI will implement to prevent a recurrence of such QAQC gaps in its documentation and communication.
 
 

Due date: 2020-04-30

Date closed: 2020-05-25
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