Compliance Verification Activity Report: CV1617-113 - Kinder Morgan Cochin ULC

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 1689

Regulated company: Kinder Morgan Cochin ULC

Operating company: Kinder Morgan Cochin ULC

Province(s) / Territory(s):

• Saskatchewan

Discipline(s):

• Safety Management

Related events:

• CV1718-251

Rationale and scope:

Verification of OPR and CLC and company-specific safety program requirements. The purpose of the inspection is to assess compliance with the NEB OPR and CLC requirements. Also where appropriate, the implementation and compliance to the general safety standards of the company.

Compliance tool(s) used:

• Assurance of Voluntary Compliance (AVC) (2)

Facility details

Facilities:

• FINDLATER PS [Canadian Western Section]
• ESTLIN PS [Canadian Western Section]
• Canadian Western Section

Facility Types

• Pipeline
• Pump station

Life-cycle Phases

• 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)
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• XO-K077-015-2013

Additional Project-specific requirements or conditions:

Observations (no outstanding follow-up required)

Observation 1 - Kinder Morgan Cochin (ULC) – General

Date & time of visit: 2017-03-01 08:00

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Fire Protection
• Flammable and Combustible Liquids
• Labels and Documentation
• Hazard Assessment
• Permanent Structures
• Stairs, Fixed Ladders and Access/Egress
• Housekeeping
• Shelving and General Storage
• Signage

Facility:

Observations:

• Orientation provided covered safety fundamentals covered.
• Personal protective equipment verified.
• Office with maintenance shop inspection observations included:
  • Washrooms supplied and clean.
  • Maintenance shop tidy.
  • Exits clearly marked with signs.
  • No-smoking signs and no evidence of smoking.
  • Rubber tired fork lift inspection records.
  • Grinder with machine guard.
  • Compressed gas cylinders properly stored, upright, capped and secure with flashback arrestors appropriately installed.
  • Fire extinguishers adjacent to exits, mounted, with monthly inspection and annual maintenance tags up to date.
  • Manufactured flammable storage cabinet in good order.
  • Shelving, secure and safely loaded with load rates labeled..
  • Oily waste can supplied, empty.
  • Mezzanine, load rated
  • Slings in good shape.
  • Drill press secured to the floor.
  • Ladders stored appropriately.
  • Emergency eye wash available.
• Viewed the Environment Health and Safety Policy Statement dated 2 February 2017.

Compliance tool used: No compliance tool used

Observation 2 - Findlater Pump Station

Date & time of visit: 2017-03-01 10:48

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Personal Protective Equipment
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Overhead Cranes
• Permanent Structures
• Housekeeping
• Shelving and General Storage
• Signage
• Noise Control
• Signage

Facility:

• FINDLATER PS [Canadian Western Section] (Facility)

Observations:

• Inspection observations included:
  • Site specific safety information provided by Company supervisor.
  • Accompanying company person equipped with portable gas detector.
  • Muster locations and windsock clearly visible.
  • Company and emergency contact number posted at main entry.
  • Site perimeter fenced, with fence in satisfactory condition and its regular inspection was discussed and asserted by the Company supervisor.
  • Company Safety Policy observed and discussed.
  • No-smoking sign posted appeared to be respected.
  • Hearing protection warnings posted visibly prior to entry into areas required.
  • Ear plugs available to all persons requiring them.
  • Emergency eyewash available.
  • Lock out tag out procedures observed and discussed.
  • Fire extinguishers observed strategically placed throughout the station.
  • Fire extinguishers with up-to-date monthly inspection and annual maintenance tags.
  • Fire extinguishers at site all of type BC.
  • Occupied building (control room) not supplied with type A fire extinguisher.
  • Danger High Voltage signs on electrical enclosure cabinets
  • ARC flash warning signs observed on electrical enclosure cabinets.
  • PPE – ARC flash wear observed, in good condition.
  • Product labels on pails. (3 ~ 20 liter pails labeled “glycol” observed in variable frequency drive room.)
  • Emergency lighting observed in control room building.
  • Operating manuals observed.
  • Ladders securely stored.
  • Whip checks in place on compressed air lines.
  • Radio tower observed and discussed as no longer in use, still with lights flashing on top.
  • ESDs observed strategically located.
  • Drain-down skid with double hearing protection when operating warning sign.
  • Drain-down stairs and platforms secure, with guardrails and slip proof walking.
  • Two storage containers kept locked.
  • Adequate signage on sub-station fence.
  • Station emergency egress gates functional.
• Propane bullet observed outside the control building.  A safety zone for traffic was delineated by bright yellow uprights and barrier chains.. The group discussed whether or not this was adequate propane tank protection from potential vehicle impact.  Company representative asserted that the visual indicators were better in snow conditions.

Compliance tool used: No compliance tool used

Observation 3 - Estlin Pump Station

Date & time of visit: 2017-03-01 15:15

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Personal Protective Equipment
• Industrial Sanitation and Personnel Facilities
• Electrical Safety
• Fire Protection
• Flammable and Combustible Liquids
• Labels and Documentation
• Hazard Assessment
• Materials Handling
• Overhead Cranes
• Permanent Structures
• Housekeeping
• Shelving and General Storage
• Signage
• Noise Control
• Signage

Facility:

• ESTLIN PS [Canadian Western Section] (Facility)

Observations:

Inspection observations included:

• Site specific safety information provided by Company supervisor.
• Accompanying company person equipped with portable gas detector. 
• Muster locations and windsock clearly visible.
• Company and emergency contact number posted at main entry.
• Site perimeter fenced, with fence in satisfactory condition and its regular inspection was discussed and asserted by the Company supervisor. The perimeter fencing had egress gates, two of which were inaccessible due to approximately one foot of  snow accumulation. Other egress gates tested and found functional.
• Company Safety Policy observed.
• No-smoking sign posted appeared to be respected.
• Hearing protection warnings posted visibly prior to entry into areas required.
• Ear plugs available to all persons requiring them.
• Lock out tag out procedures observed and discussed.
• Fire extinguishers observed strategically placed throughout the station.
• Fire extinguishers with up-to-date monthly inspection and annual maintenance tags.
• Fire extinguishers at site all of type BC.
• Occupied building (control room) not supplied with type A fire extinguisher.
• Danger High Voltage signs on electrical enclosure cabinets
• ARC flash warning signs observed on electrical enclosure cabinets.
• PPE – ARC flash wear observed, in good condition.
• Product labels on pails. (20 liter pails labeled “glycol” and drum of "ethylene glycol" observed in variable frequency drive room.)
• Emergency lighting observed in control room building.
• Operating manuals observed.
• Ladders securely stored.
• Propane tank observed outside in chained off area. The group discussed propane tank protection from potential vehicle impact.
• Radio tower observed and discussed as no longer in use.
• ESDs observed strategically located.
• Drain-down skid with double hearing protection when operating warning sign.
• Drain-down stairs and platforms secure, with guardrails and slip proof walking.
• Portable power light generator, not operating, with ABC fire extinguisher observed and positive air shut off indicated by sign.
• Rig mats in place along pipe assembly said due to facilitating recent and ongoing maintenance.
• Noise assessment observed.
• Inspection records examined.

Compliance tool used: No compliance tool used

There are no observations with outstanding follow-up

Observation 4 - Estlin Pump Station Emergency Egress Gates

Date & time of visit: 2017-03-01 14:30

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding
• Hazard Assessment

Facility:

• ESTLIN PS [Canadian Western Section] (Facility)

Observations:

Two emergency egress gates, though capable of functioning, were blocked with snow and would not open.  The company was planning to conduct work at the station in the days following the inspection.  Egress gates should be functional any time workers are present.  This issue was discussed with company staff; however, an NNC was not issued as changing weather conditions would make doing so irrelevant..

Compliance tool used: No compliance tool used

Observation 5 - Station Traffic Patterns

Date & time of visit: 2017-03-01 14:45

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Safeguarding

Facility:

• ESTLIN PS [Canadian Western Section] (Facility)

Observations:

NEB staff observed that no path for vehicle and equipment traffic in the pump stations was delineated.  Not having a clearly delineated path or other positive method of traffic control could result in vehicle encroachment adjacent to pipe risers, above underground pipelines and other critical infrastructure.  For instance, vehicle tracks in the ground were observed very close to a pipe at the location where it rises out of the ground. 

Suggestion:  Companies should determine and delineate the safe path(s) of vehicle and equipment travel within the fenced areas of facilities as a best practice to protect all piping and other critical infrastructure. 

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:

Observation 6 - 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

Observation 7 - 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