Compliance verification activity type: Field Inspection
Team:
Regulated company: Westcoast Energy Inc., carrying on business as Spectra Energy Transmission
Operating company: Westcoast Energy Inc., carrying on business as Spectra Energy Transmission
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Construction inspection of the High Pine Expansion project to follow up on Inspection Officer Order RRW-001-2017 and RRW-002-2017, as well as other environmental focus areas. In addition, conduct follow-up on contactor oversight with specific review of Field Level Hazard Assessments review by prime of sub-contactor and operator review of prime and their oversight of their contractors. Weather for the inspection was raining on Oct 24, and the site was shut down on Oct 25 due to record snow fall in the Ft. St. John area. Site was shut down due to weather and difficultly getting around and safety working and environmental concerns that could develop due to risks of mudding and erosion that could be created if operations continued. Two sites were visited by environment and two by safety before inspection was timed out due to weather and end off operations. No pipe handling was observed as this operation was not visited due to access and limited time due to soil conditions (mud). On Oct 25, records were reviewed in the field office.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
There are no observations with outstanding follow-up
Observation 1 - Safety Field Inspection Bell Hole at Pipeline Welding Shack (Poor Boy Welding)
Date & time of visit: 2017-10-24 14:24
Discipline: Safety Management
Categories:
Facility:
Observations:
Upon arriving at the worksite, a detailed FLHA was presented and reviewed. It was detailed, complete and legible. activity at the site was poor boy welding. Enbridge welding inspector was in the entrance to the welding shack which was in the ditch. Ventilation for the shack appeared satisfactory as the vents were open and fumes were being exhausted. An Equipment Safety Checklist was available for the 349F side boom unit #216. It was complete and had been signed both by the operator and the foreman. It was noted that the broken blind side mirror was noted and due to be repaired. The side boom had an environmental sticker on the side verifying that the equipment had been checked for being weed and leak free at the time it was inspected prior to arrival on site. Access and egress ladders were present, at the require extension of three rungs, at the required spacing and staked and wired off. It was noted that the end of one ladder that plastic cap had been damaged and was not present. When mentioned it was quickly taped up to prevent a cutting edge while using the ladder.Slings were present and in satisfactory condition with weight indication tags were present and legible. There were no concerns at this site.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Enbridge is to submitted doucmentation to verify that Both Enbridge and Sureus Murphy Joiny Ventures as ensuring that both the Prime Contractor and sub-Prime company FLHA is reviewed for completeness and quality assurance.
Due date: 2017-10-24
Date closed: 2017-10-24 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 - Safety Management Document Review and CNC regarding Contractor Oversight (FLHA)
Date & time of visit: 2017-10-25 13:00
Document Review and Follow-up verification that Contractor Oversight had been corrected regarding FLHA'sOn a previous inspection, CV1718-272 conducted Aug 16, 2017, it was noted thru document review that a regular review of FLHA was not being conducted on a subprime (McCaw's) to SMJV and that neither Enbridge or SMJV could satisfactory demonstrate to the inspector that a review was being conducted. In response to that inspection CV1718-272, Enbridge stated the following:
Hazard ID Safety Assurance Tool
• Current program requires Enbridge field safety specialist to regularly attest the quality of the general contractor tailgate and hazard identification systems (FLHA) at the field level) o Every assessment submitted has evidence attached (a contractor FL
o Each field specialist is required to complete a set amount of these assessments a month
o Every project has a scaled number of specialists based on risk, activity and the number of workers
• Assessments and evidence of reviews are recorded on a secure network SharePoint system. Data entered is logged by the user ID (our electronic version of signing a form) o Evidence for every submission is an attachment of the contractor FLHA reviewed in the field
• Monthly and quarterly reports are reviewed with project leadership to attest the safety "health" of the project
• ACTION – adjust assessment criteria of safety specialist to include a defined portion (25%) of their QA/QC activities to focus on sub-contractors (ie. McCaws Blasting subcontracted to SMJV)".
As the project was shut down for several days due to weather conditions, prior to start up, Enbridge is to develop a more rigorous method of ensuring compliance for prime and contactor oversight specifically regarding qualitative review of FLHA's. As this is the second offense, Enbridge is to submit to the NEB inspector documentation verifying that qualitative assessments have been conducted on both FLHA's and Tailgate cards.Documentation will be submitted to the inspector evey Monday morning until construction conclusion.
Due date: 2017-10-25
Date closed: 2017-10-30 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.
Observation 3 - Watercourse Crossing #26 Tributary to Pine River
Date & time of visit: 2017-10-24 12:30
Discipline: Environmental Protection
Conditions along the RoW were very wet and muddy and crews shut down at 2:00 pm. Two large diversion berms and sediment fence were in place on the steep slope protecting the watercourse. The banks were lined with integrated log boxes and were well constructed. A couple more log tiers will be be added to the height. Geotextile soil wraps were installed and the contractor will be adding additional rocks and boulders from a local quarry to the watercourse bed and banks. The Environmental Inspector confirmed Landsong monitors were cutting and collecting willows to be installed into the log boxes as per the site specific reclamation plan.
Compliance tool used: No compliance tool used
Observation 4 - Watercourse Crossing #16 Highrise Creek
Date & time of visit: 2017-10-24 14:20
Crews were shut down for the day due to wet weather conditions. An additional watercourse crossing crew will be working to complete the crossings and an erosion specialist will be joining the project. Coconut matting and two layers of sediment fence were adequately installed and test drilling was complete. The bridge wrapped in geotextile was fairly clean and additional cleaning supplies were on site. The old growth forest and traditional ecological knowledge and archaeological sites were identified with signage and flagging. No fueling within 100m of the watercourse signs were installed and topsoil and subsoil piles were marked and identified with specific colored stakes.
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
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