Compliance Verification Activity Report: CV1718-265 - Trans Mountain Pipeline ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 1137

Regulated company: Trans Mountain Pipeline ULC

Operating company: Trans Mountain Pipeline ULC

Province(s) / Territory(s):

• British Columbia

Discipline(s):

• Safety Management

Rationale and scope:

Construction inspection of the Trans Mountain Pipeline Expansion Project. Westridge Terminal, Burnaby Terminal and Sumas Pump Station. Focus was on contractor management activities, site-specific hazards identified in the construction safety manuals and in-water safety measures.

Compliance tool(s) used:

• Corrected Non-compliance (CNC) (2)
• Information Request (IR) (1)

Facility details

Facilities:

• BURNABY
• TRANS MOUNTAIN EXPANSION PROJECT
• SUMAS

Facility Types

• Pipeline
• Pump station
• Terminal

Life-cycle Phases

• Construction
• Operations

Regulatory requirements

Regulatory requirements that apply to this activity:

• Canada Labour Code (CLC)
• Canada Labour Code (CLC)
• Canada Occupational Health and Safety Regulations (COHSR) 2016-06-14
• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) 2016-06-19
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Observations (no outstanding follow-up required)

Observation 1 - Burnaby Storage Tank Facility- General Observations

Date & time of visit: 2018-01-10 08:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Hazard Assessment
• Materials Handling
• Overhead Cranes
• Ropes, Chains and Slings
• Permanent Structures
• Stairs, Fixed Ladders and Access/Egress
• Housekeeping
• Signage
• Lighting
• General Lighting
• Training and Competency
• Training, Competency and Qualification

Facility:

• BURNABY (Facility)

Observations:

• the facility was tidy and showed evidence of effective housekeeping
• shelves were observed with load ratings and were securely fastened
• yard piping was marked with direction of flow and content
• fall arrest gear was observed to be in good condition
• All operators are certified in Fall Arrest and Confined Space training
• workers were observed wearing appropriate PPE
• Lock out/tag out (LOTO) process appered to be in good order
• Shops inspected at the Terminal were also neat and clean
• Mobile equipmwent in the yard have pre-use checklists and all diesel equipment inspected have Positive Air Shutoffs (PASO)
• One sling appeared to be frayed, it was removed and destroyed (CNC)

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 36. A company shall
    • (b) periodically test instruments and equipment at the pipeline stations to verify their proper and safe operation;

Company action required:

No further action required for the damaged sling but an IR has been sent to identify the process for slings and rigging equipment.

Due date: 2018-01-10

Date closed: 2018-01-10
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 - Westridge Marine Terminal - General Observations

Date & time of visit: 2018-01-10 14:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Temporary Structures
• Scaffolding and Temporary Ladders
• Temporary Stairs, Ramps and Platforms
• Signage
• Lighting
• General Lighting
• Noise Control
• Signage
• Monitoring/Evaluation
• Training and Competency
• Training, Competency and Qualification

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

• staging for future work was ongoing
• ancillary equipment neatly organized
• piling was halted for a duration of approximately one hour due to a seal sighting
• site orientation was comprehensive and well-delivered
• site housekeeping was effective, which was important given the tight working spaces along the shoreline
• PFD's were observed being used by those workers on the barges and are mandatory within 2 metres of the water 
• PPE was observed in use
• Ambulance is on site
• KM is maintaining Terminal operations including Tanker loading when required.

Compliance tool used: No compliance tool used

Observation 3 - Sumas Pump Station - General Comments

Date & time of visit: 2018-01-11 12:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Electrical Safety
• Fire Protection
• Materials Handling
• Overhead Cranes
• Ropes, Chains and Slings
• Permanent Structures
• Stairs, Fixed Ladders and Access/Egress
• Signage
• Noise Control
• Monitoring/Evaluation

Facility:

• SUMAS (Facility)

Observations:

• the facility was tidy and showed evidence of effective housekeeping
• shelves were observed with load ratings and were securely fastened
• yard piping was clearly marked with direction of flow and content
• fall arrest gear was observed to be in good condition
• workers were observed wearing appropriate PPE
• an infomation request has been issued pertaining to all locations.

Compliance tool used: No compliance tool used

Observation 4 - Information Request

Date & time of visit: 2018-01-11 15:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Materials Handling
• Overhead Cranes
• Ropes, Chains and Slings
• Noise Control
• Signage

Facility:

• TRANS MOUNTAIN EXPANSION PROJECT (Pipeline)

Observations:

We request that TransMountain provide a response to the following questions pertaining to the Westridge Marine Terminal:
 

• Process for verifying competency and records of training of TransMountain inspectors, specifically including their competency in their respective functional tasks they supervise. 
• What TransMountain requires at a minimum for inspection/supervisory checks of work by TransMountain of its contractors. 
• The contractors’ process for verifying supervision and a sample of records or documentation indicating this is being performed.
• A chart outlining the reporting responsibilities for TransMountain contractor’s.
• A process/procedure for ensuring all diesel vehicles entering the WMT (or all areas deemed “hazardous”)are equipped with Positive Air Shutoffs (PASO).

•  A process/procedure for ensuring all hoisting and rigging equipment is checked and maintained (chains and slings specifically). Please verify that all hoisting and rigging equipment, including com-along’s and pallet jacks, are on a preventive maintenance program.
•  A process/procedure for ensuring all mobile equipment is checked and maintained as required by TransMountain; provide a sample of completed log books.
• Verify that where hazardous chemicals are handled, an appropriate volume of eye wash is immediately available as recommended by the most current SDS.
• Please provide the last 2 annual inspections conducted on all overhead cranes at the Burnaby Terminal.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 6. When a company designs, constructs, operates or abandons a pipeline, it shall do so in a manner that ensures
    • (a) the safety and security of the public and the company’s employees;
    • (b) the safety and security of the pipeline; and
    • (c) the protection of property and the environment.

Company action required:

Please respond to the Information Request by 8 Feb, 2018.

Due date: 2018-02-08

Date closed: 2018-02-16
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

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 5 - 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