Compliance Verification Activity Report: CV1617-514 - TransCanada PipeLines Limited

Overview

Compliance verification activity type: Field Inspection

Team:

• Inspector 1137
• Inspector In Training 2773T
• Inspector In Training 2735T

Regulated company: TransCanada PipeLines Limited

Operating company: TransCanada PipeLines Limited

Province(s) / Territory(s):

• Ontario

Discipline(s):

• Safety Management

Related events:

• CV1617-515

Rationale and scope:

Field inspection of construction activities occurring on the Vaughan Mainline Expansion project. Verification of compliance with company-specific program and OPR requirements. Construction Safety Manual screening done prior to field inspection (1617-515).

Compliance tool(s) used:

• Information Request (IR) (1)

Facility details

Facilities:

• VAUGHAN MAINLINE EXPANSION

Facility Types

• Pipeline
• Pipeline

Life-cycle Phases

• Construction

Regulatory requirements

Regulatory requirements that apply to this activity:

• National Energy Board Act (NEBA)
• Onshore Pipeline Regulations (OPR)
• National Energy Board Act (NEBA) 2016-06-19
• Plans And Procedures
• Project-specific Contractor/Project Safety Plan (CSP)
• Vaughan Mainline Expansion Banister/Project Specific Safety Plan | November 14 2016
• Standards
• CSA Z662-15 - Oil and Gas Pipeline Systems

Regulatory instrument number(s):

• XG-T211-020-2016

Observations (no outstanding follow-up required)

Observation 1 - Project Yard, Office - Trailers and Storage Site

Date & time of visit: 2017-01-25 09:00

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
• Permanent Structures
• Stairs, Fixed Ladders and Access/Egress
• Housekeeping
• Shelving and General Storage
• Signage
• Temporary Structures
• Temporary Stairs, Ramps and Platforms
• Signage
• Noise Control
• Signage

Facility:

• VAUGHAN MAINLINE EXPANSION (Pipeline)

Observations:

TransCanada representatives accompanied the NEB inspection team on a walkabout inspection of facilities operated by its contractor, Banister, at 12380 Albion Road. The walkabout inspection included the Project Office, Storage Trailers and Storage Yard.

Observations made:

• Signs were strategically positioned to inform of prohibited unauthorized access, the personal protective equipment (PPE) required and the Company's contact number.
• Walkways and stairs were unobstructed and slip resistant with railing.
• Washroom facilities were clean and supplied.
• Walking areas in parking lot and around storage yard were unobstructed and graded.
• Materials in yard were neatly stored and organized.
• Bottles and tanks were properly stored on racks, secured by belts, with caps on and separated.
• Light generators and fuel tank facilities were grounded.
• Vehicle parking was safely done in accordance with safety measures prescribed by Company procedures.
• Tailgate and Field Level Hazard Asssesemnt (FLHA) were performed for the inspection.
• No smoking signs were observed in Supply Trailer.
• Shelving was observed safely loaded in the SupplyTrailer.
• Temporary lighting was removed from service.
• Fork lift was observed and left properly secured.
• Slings were observed to be in good condition.
• Equipment inspection and operator competency processes were explained to NEB the inspection team.
• Fuel tanks and fueling area was properly signed, grounded and with spill containment.
• During the inspection, a number of portable fire extinguishers in the trailers occupied by employees were examined. All examined extinguisher pressure gauges indicated an operable range and monthly inspection tags were up to date. Inspectors were unable to determine from tags though that annual maintenance was performed.  During a closing meeting, the NEB inspection team advised the Company's representatives that a request would be made for further information to confirm compliance with fire exteinguisher maintenance requirements.

Compliance tool used: Information Request (IR)

Regulatory requirement:

• Onshore Pipeline Regulations (OPR)

Relevant section(s):

• • 4. General
    • (2) Without limiting the generality of subsection (1), the company shall ensure that the pipeline is designed, constructed, operated or abandoned in accordance with the design, specifications, programs, manuals, procedures, measures and plans developed and implemented by the company in accordance with these Regulations.
  • 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;

Company action required:

Information Request
An information request (IR) was sent by email to the Company to provide explanation for the absence of the properly completed tags or labels required by NFPA 10 “7.3.4 Annual Maintenance Record Keeping,” on the fire extinguishers observed at the 12380 Albion Vaughan Road site.
 

Due date: 2017-02-13

Date closed: 2017-02-10
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 - General "Shoofly" Observations

Date & time of visit: 2017-02-25 13:25

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Personal Protective Equipment
• Fire Protection
• Hazard Assessment
• Temporary Structures
• Temporary Stairs, Ramps and Platforms
• Signage

Facility:

• VAUGHAN MAINLINE EXPANSION (Pipeline)

Observations:

Terminology
"Shoofly" - Jargon - a term used on the pipeline project to refer to the temporary thoroughfare by which a construction worksite is accessed.

• Access was controlled around-the-clock at each shoofly by security personnel stationed at the gate.
• Personnel on site wore required personal protective equipment.
• Barrier fencing posts were cappped to protect from hazard of sharp object.
• Fencing, warning signage and vigilance of personnel also helped ensure access control at each worksite.
• Extensive rig matting was used providing a good walking and driving surface, despite wet weather and otherwise muddy conditions.
• Fire protection equipment in form of portable extinguishers was in place at each worksite.
• Supervision was provided at each site by site supervisor/foreman.
• The construction safety manual was accessible through the site foreman to every person involved in construction activity.
• Site foreman had a copy of the emergency response plan was and a copy was provided to the NEB inspection team.
• Construction peronnel displayed alertness and exhibited competency when observed conducting Field Level Hazard Assessments (FLHA) or when explaining their role and work responsibilities to the NEB inspection team.
• The process of equipment maintenance checks, including being performed prior to the start of every shift, was explianed to the NEB inspection team.

Compliance tool used: No compliance tool used

Observation 3 - Shoofly 9 - Humber River Drilling Site

Date & time of visit: 2017-01-24 11:35

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Personal Protective Equipment
• Fire Protection
• Hazard Assessment
• Temporary Structures
• Scaffolding and Temporary Ladders
• Temporary Stairs, Ramps and Platforms
• Signage

Facility:

• VAUGHAN MAINLINE EXPANSION (Pipeline)

Observations:

• Goal post in place marking overhead lines.
• Muster points observed and clearly indicated.
• Outdoor toilet facilities provided.
• Designated smoking area observed.
• Tailgate and Field Level Hazard Assessment was performed.
• Drilling observation observed and explained by the drill operations staff.
• Fire Extinguisher observed with up to date monthly tag.
• Eye wash station with up to date monthly tag. 
• Shelving was secured to wall and safely loaded.
• Hearing protection was worn.
• Horizontal Directional Drilling (HDD) rig was clean of debris and pressure washing observed.
• During tour of facility, the walkways, stairs, railing and platforms were secure and in good condition.
• Continual vibration monitoring process explained to NEB inspection team.

Compliance tool used: No compliance tool used

Observation 4 - Shoofly 10 - Pipe unloading.

Date & time of visit: 2017-01-24 12:52

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Personal Protective Equipment
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Temporary Structures
• Temporary Stairs, Ramps and Platforms
• Signage

Facility:

• VAUGHAN MAINLINE EXPANSION (Pipeline)

Observations:

• Security personnel were positioned at site entry checking persons entering.
• The site had security fencing and warning signage in place.
• Extensive rig matting was in place providing good walking and working areas, despite wet conditions. 
• An excavator was equipped with nylon pickers, safely unloading pipe from flatdeck of truck onto secure dunnage/cribbing.
• Employees dressed appropriately for the cold weather and with personal protective equipment.
• The excavator was securely parked after use.

Compliance tool used: No compliance tool used

Observation 5 - Shoofly 11 & 12 - Highway Crossing - Slip Bore - Site

Date & time of visit: 2017-01-24 13:25

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Personal Protective Equipment
• Fire Protection
• Hazard Assessment
• Materials Handling
• Mobile Cranes and Hoisting Equipment
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Temporary Structures
• Scaffolding and Temporary Ladders
• Temporary Stairs, Ramps and Platforms
• Signage

Facility:

• VAUGHAN MAINLINE EXPANSION (Pipeline)

Observations:

• Pipe observed securely stowed at work site.
• Slip bore process explained to NEB inspection team.
• Area excavated protected by fencing and warning signage.
• Light plant/generator grounded, with wheels chocked, with fire extingusher and spill containment.
• Daily tailgate/FLHA thorough and well communicated. 
• Track Hoe operator competency verification process explained to NEB inspection team, including records for contractor oversight.
• Track Hoe operator daily excavation entry checklist examined and verified.
• Slings observed to be in good condition.
• Ladders in place in compliance with egress requirement.
• Daily pre-job practice of calibration of personal gas detection monitors explained to NEB inspection team.
• Security process explained to NEB inspection team, including doors locked on motorized materials handling equipment.

Compliance tool used: No compliance tool used

Observation 6 - Shoofly 14 - Watercourse 33

Date & time of visit: 2017-01-25 14:52

Discipline: Safety Management

Categories:

• Workplace Exposures and Protections
• Personal Protective Equipment
• Fire Protection
• Hazard Assessment
• Materials Handling
• Ropes, Chains and Slings
• Haulage and Off-Road Equipment
• Temporary Structures
• Temporary Stairs, Ramps and Platforms
• Signage

Facility:

• VAUGHAN MAINLINE EXPANSION (Pipeline)

Observations:

• Extensive rig matting used preventing hazard from slipping in muddy soil conditions.
• Added traction control including on slope with use of rock particulate (gravel).
• Heavy Equipment left unattended was observed properly secured. 
• Slings observed to be in good condition.
• Generator for lighting was grounded.
• Quality control process of bolting of the temporary open-bottom culvert observed and explained.
• Employees alert, and wearing personal protective equipment.

Compliance tool used: No compliance tool used

Observations (company follow-up required)

Identified non-compliances to company plans or procedures are non-compliances either to: