Compliance verification activity type: Field Inspection
Team:
Regulated company: Plains Midstream Canada ULC
Operating company: Plains Midstream Canada ULC
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Assess compliance with the OPR and company-specific program requirements. Focus areas are to include Permitting, LOTO, Confined Space Entry, Hoisting and Rigging, Ground Disturbance.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - General Observations - Richardson Terminal
Date & time of visit: 2018-03-12 15:20
Discipline: Safety Management
Categories:
Facility:
Observations:
- emergency contact information and no smoking signage present at front gate- housekeeping was generally organized and tidy throughout the facility, but the maintenance shop could be attended to- outdoor storage of compressed gases was organized and secure- overhead cranes - annual inspections and certifications were completed- Positive Air Shutoff (PASO) equipped vehicles were required at this site- shelving had load ratings- pre-use equipment checks present for mobile equipment- fire extinguishers had overdue annual inspections maintenance, but were inspected on a monthly basis- hazardous material liquid storage had secondary containment- electrical panels were easily accessible- eye wash stations were present and had inspections as required- even though a heavy snowfall had occurred recently, pathways and emergency exit access points in the facility had been cleared- buildings were grounded- review of work permits at this location noted some deficiencies that should be addressed by local management, such as: not cross-referencing work permit to safe work plan, some permits not signed, some permits did not reference standards and procedures, some permits did not adequately identify or label the hazards
Compliance tool used: No compliance tool used
Observation 2 - NNC Fire Extinguisher Annual Inspections - Richardson Terminal
Date & time of visit: 2018-03-12 16:06
All of the fire extinguishers on the site had not had their annual inspections completed. Monthly visual inspections were conducted by company staff as required, but the annual inspections were overdue. Company identified the cause as being due to difficulty with their contracted maintenance company.
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
The company shall ensure that the annual inspections of fire extinguishers is completed by April 30th, 2018 and provide a report in writing that confirms the work has been completed.
Due date: 2018-04-30
Date closed: 2018-04-18 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 3 - NNC Hoist and Crane Inspections - Richardson Terminal
Date & time of visit: 2018-03-12 16:44
There is a fixed crane located in the De-Hy Building. There are no records to indicate that monthly inspections have been conducted. PMC staff told NEB inspectors that staff conduct pre-use inspections and the cranes are inspected annually. Prior to 2016, this facility was owned and operated by another pipeline company that did not require monthly inspections and the new policy was never implemented. The annual inspection tag was valid and up to date.
Follow the company requirement to inspect cranes monthly effective immediately. Forward a copy of the first monthly inspection report as documented on PMC's Hoist and Cranes Inspection Form.
Observation 4 - General Observations - Grenfell Station
Date & time of visit: 2018-03-13 08:24
- housekeeping was organized and tidy throughout the facility- facility inspections were conducted as per the inspection standard- shelving had load ratings- fire extinguishers had annual maintenance completed, and were inspected on a monthly basis - hazardous material liquid storage had secondary containment- electrical panels were easily accessible
Observation 5 - General Observations - Manson Station
Date & time of visit: 2018-03-13 11:48
- housekeeping was organized and tidy throughout the facility- shelving had load ratings- pre-use equipment checks present for mobile equipment- fire extinguishers had monthly and annual inspections- ladders and equipment were secured against walls- PPE on site- hazardous material liquid storage had secondary containment- electrical panels were accessible- eye wash stations were present and had inspections as required- a heavy snowfall had occurred recently, facility had not been cleared- no smoking sign at gate was attached to fence in a manner that make it difficult to see when the gate is open
Observation 6 - General Observations - Rapid City Terminal
Date & time of visit: 2018-03-14 09:13
- received site specific orientation and tour- housekeeping was organized and tidy throughout the facility- outdoor storage of compressed gases was organized and secure- shelving had load ratings- pre-use equipment checks present for mobile equipment- fire extinguishers had annual and monthly inspections completed- hazardous material liquid storage had secondary containment- electrical panels were easily accessible- eye wash stations were present and had inspections as required- snow clearing and site accessibility very good - no audible ESD alarm at this location due to proximity of neighbours- emergency contact and no smoking signage present on gate
Observation 7 - General Observations - Fort Whyte Terminal
Date & time of visit: 2018-03-15 08:00
- this location contains storage tanks, has sales tanks for truck loading, and a CP Rail spur line into the facility for loading of up to 13 rail cars- emergency contact information and no smoking signage present at front gate- housekeeping was well organized and tidy throughout the facility- outdoor storage of compressed gases was organized and secure- overhead cranes - monthly and annual inspections and certifications were up to date- Positive Air Shutoff (PASO) equipped vehicles were required at this site and company conducted carrier audits and provided documenation of such- shelving had load ratings with the exception of 5 shelves in the maintenance shop (addressed in another Observation)- pre-use equipment checks present for mobile equipment- fire extinguishers had monthly and annual inspections maintenance- second floor records storage - shelves were organized and labelled- hazardous material liquid storage had secondary containment- electrical panels were easily accessible- eye wash stations were present and had inspections as required- appropriate safety equipment was present where required- ladders and other equipment were properly secured- review of work permits at this location noted few deficiencies- slings has manufacturer labels present and in good condition- engineering fall protection present for worknig at heights during rail loading
Observation 8 - CNC Shelving Load Ratings - Fort Whyte Station
Date & time of visit: 2018-03-16 09:57
Warehouse #2 at the Fort Whyte Station contains five (5) shelving units that are not load rated and are currently being used to store equipment and tools. Company staff informed NEB staff that these shelving units were custom built and they did not have load ratings available, so they had contracted a company to provide an engineering assessment to load rate the shelves. The company took the shelves out of service until the work can be completed, therefore this was deemed a corrected non-compliance. Five photos attached of shelves out of service.
Compliance tool used: Corrected Non-compliance (CNC)
The company will continue to keep these shelving units out of service until either the shelves are taken out of service permanently or the load capacity is assessed and rated by a competent person.
Due date: 2018-03-16
Date closed: 2018-03-16 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.
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