Compliance verification activity type: Field Inspection
Team:
Regulated company: Husky Oil Operations Limited
Operating company: Husky Oil Operations Limited (HOOL)
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Field Inspection of Husky Oil Operations Limited (HOOL). Safety Program focus, to verify compliance with the National Energy Board Onshore Pipeline Regulations (OPR) and company-specific requirements for ongoing operations and maintenance activities.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Safety Program – General Observations
Date & time of visit: 2019-03-05 11:00
Discipline: Safety Management
Categories:
Facility:
Observations:
Orientation – Husky Oil Operations Limited provided NEB Officers with a Husky Midstream Visitor Site Specific Orientation, an overview of both the Lloydminster Terminal/NGL Site-Specific Field Orientation documentation, and Lloydminster Terminal & Associated LACT Units Routine Operations Hazards and Controls documentation. Overview - Husky Representatives provided and discussed a summary of their NEB-regulated facilities and pipelines. Husky Oil Operations Limited (HOOL), owns and operates the four lines associated with NEB Order XO-6-91 known as the Border Pipeline System consisting of a Heavy Crude Oil Line, Refinery By-Product Liquid Line which both flow from the Lloydminster Terminal to the Lloydminster Upgrader, as well as the Recycle Diluent Line (6BPLD) and the Light Crude Oil Line, which flow product from the Lloydminster Upgrader to the Lloydminster Terminal. Opening Documents - Husky Representatives provided NEB Officers with a copy of Husky Midstream Corporate Structure / Organizational Structure Diagram and summary of O&M activities from October 2018 – March 2019 inclusive. Safety Policy – Husky Representatives provided and discussed an electronic copy HSE Corporate Policy statement, HOIMS Brochure – Element Book, and Code of Business Conduct Policy, and provided and discussed examples of how the company communicates the policies, and demonstrated where the documents can be accessed by employees. Hazard Identification and Risk Assessment – Husky Representatives provided and discussed electronic copies and overview of Hazard Assessment – Technical Standard (Corporate), Risk Management Standard (Corporate), Task Observation Program Procedure (Midstream), Maintaining Safety Procedures (Midstream), and Safety Management Plan (Midstream). Husky Representatives explained the process for identifying and analyzing safety hazards through various programs such as site specific hazard assessments, and provided and discussed an electronic copy of Task Observation Spreadsheet as an example. Hazard Communication – Husky Representatives explained how hazards and controls are communicated, and provided and discussed examples via Safety Meetings and Meeting Minutes, and Monthly MSDS Tracking Spreadsheet. Husky Midstream advised their top three occupationa hazards are Working Alone, Driving, and Chemical products. Operations and Maintenance Manual(s) – Husky Representatives provided and discussed an electronic copy and overview of its Safe Operations Standard, associated manual, provided and discussed electronic documentation including examples of Right of Way (RoW) Aerial Surveillance Procedure, Leak Detection, Aerial Reports, as well as pigging activities. NEB Officers verified a recent aerial patrol report and confirmed Husky Midstream is not reporting by exception. Contractor Oversight - Husky Representatives provided and discussed electronic copies and overview of Contracted Services and Materials (Corporate), Task Observation Program Procedure (Midstream), and Safety Management Plan. Husky Midstream provided and discussed electronic documentation examples of SharePoint ‘Orientation Site’ and Task Observation Spreadsheet. Husky Representatives indicated that Husky Midstream ensures contractors have safety programs, work is audited, and that proper work permits are obtained prior to doing any work. Management of change (MOC) – Husky Representatives provided and discussed electronic copies and overview of MOC Procedure (Corporate), MOC Standard (Corporate), HMGP MOC Standard (Midstream) and HMGP MOC Procedure (Midstream). Husky Midstream provided and discussed electronic documentation example of an Audit. Documentation and Document Control – Husky Representatives explained and confirmed its Information Management Standard, Record Management Standard, and Information Management Standard, as well as, provided and discussed electronic documentation examples of Major Projects – HMGP Procedure, and SharePoint Site – Hazards, Forms, and Templates. Performance and compliance – Husky Midstream provided and discussed electronic copies and overview of Performance Management and Continuous Improvement Standard (Corporate), Performance Management and Continuous Improvement Procedure (Corporate), Personnel Competency and Training Procedure (Corporate), Maintaining Safety Procedures (Midstream), and Safety Management Plan (Midstream). Husky Midstream provided electronic copies and discussed their Safety Recognition Program, 2018 Pipeline Scorecard Spreadsheet, and Operational Integrity Snapshot 2018-12. Recent O&M Activities – Husky Representatives discussed recent Operations and Maintenance Activities (O&M Activities), within the past six months, occurring along the 6BPLD Line, and advised 18 of 20 scheduled O&M Activities had been completed. Husky Representatives provided electronic copies and discussed 6BPLD Examples including Kickoff information, Ground Disturbance Authorization, and the Ground Disturbance Reconciliation Form “Job Book”.
Compliance tool used: No compliance tool used
Observation 2 - Operations and Maintenance Activities – General Observations
Date & time of visit: 2019-03-05 13:00
Control Room
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