Compliance verification activity type: Field Inspection
Team:
Regulated company: TransCanada PipeLines Limited
Operating company: TransCanada PipeLines Limited
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Inspection of pipeline facilities and potentially O&M, specifically Douglastown Station and area. Verify compliance to the OPR, CLC and company-specific requirements.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - General Observations
Date & time of visit: 2018-06-06 14:00
Discipline: Safety Management
Categories:
Facility:
Observations:
Compliance tool used: No compliance tool used
Observation 2 - NNC #1: Chain Winch
Date & time of visit: 2018-06-06 11:45
A 1.5T chain winch (come-a-long) was observed with inspection tag in place and hanging on the wall with similar devices in a ready state for use. When checking the inspection log it was noted that the contracting company utilized by TCPL to inspect these devices had noted that the chain dead end stop was missing and had recommended that this come-a-along be locked out of service until the issue was addressed. This same observation was noted for the same device and recorded on the same inspection form on 18th of May, 2017 and again on 3rd of May, 2018.
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
TCPL is to ensure that the device is removed from service until the issue is addressed and to determine how their existing processes did not ensure that corrective actions were implemented as recommended by the independent crane technician. Dependent on the outcome of this assessment, TCPL shall communicate and implement their revised processes across the company as relevant. Please provide details of actions taken to prevent a recurrence of this unsafe condition.
Due date: 2018-08-24
Date closed: 2018-08-27 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 #2 Skid Steer
Date & time of visit: 2018-06-06 12:10
A skid steer was observed on site that had been rented from a local supplier. There was no inspection log book provided by the rental company and TCPL did not utilize one prior to using this equipment. TCPL is therefore unable to demonstrate that this equipment had been properly inspected (TCPL”s Heavy Mobile Equipment Procedure, s.4.5. - Heavy Equipment Operators).
TCPL shall ensure that all heavy mobile equipment used by its employees, which includes rental equipment, is inspected as per company requirements and is adequately documented. Please provide details of actions taken to prevent a recurrence of this unsafe condition.
Observation 4 - Information Request - Contractor Oversight
Based on interviews of TCPL staff with the responsibility and role of Active Control/Authorized TransCanada Representative (Active Control Procedure, section 4.6 “Manage, Monitor and Control Project/Work”), it was identified that supporting documentation was not available to demonstrate compliance with this company requirement. Specifically, there were no records available to confirm that the determined frequency of oversight was based on the defined methodology. In addition, there were no records to confirm that oversight was conducted as determined.
Compliance tool used: Information Request (IR)
Please provide an explanation and supporting documentation if available of how TCPL ensures that requirements of this procedure (specifically s.4.6 item 2 and 5) are achieved.
Date closed: 2018-10-31 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
