Compliance Verification Activity Report: CV1718-364 - Westcoast Energy Inc., carrying on business as Spectra Energy Transmission

Overview

Compliance verification activity type: Field Inspection

Activity #: CV1718-364
Start date: 2018-03-20
End date: 2018-03-22

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:

Assess compliance with the OPR, CLC and company-specific requirements at the Wyndwood Expansion Project. Focus on pipe-handling procedures and any outstanding deficiencies noted in past inspections of this project. Review and inspect contractor oversight with specific review of Field Level Hazard Assessments by prime contractors.

Compliance tool(s) used:

Facility details

Facilities:

Regulatory requirements

Regulatory requirements that apply to this activity:

Regulatory instrument number(s):

Observations (no outstanding follow-up required)

Observation 1 - General Observations

Date & time of visit: 2018-03-20 07:00

Discipline: Safety Management

Categories:

Facility:

Observations:

March 20, 2018 Ledcor Offices 55.688024 -121.628957
NEB inspectors had previously taken the Westcoast carrying on business as Spectra (Spectra) Corporate orientation, prior to this inspection.  On March 20, 2018 inspectors attended a very comprehesive Ledcor Project Safety Orientation.  This orientation addressed safety commitments, requirements and expections for management, as well as for workers.  Environmental considerations were also discussed.  The orientation was very informative and several additional discussions were encouraged to further reinforce Enbridge policy, procedures and expectations for Ledcor workers and their sub-contractors.  Additional information that was discussed at the orientation were lessons learned by Spectra in the High Pine Expansion and a presentation about the two major incidents that occurred on the project (Marooka and Crew truck roll over).

Following the orientation, NEB inspectors, Spectra/Enbridge management and Ledcor representatives conducted their opening meeting (participants in the meeting are included in the opening meeting section). 
During the meeting, NEB inspectors discussed the scope of the inspection, inspector enforcement tools & powers, as well as, requesting documentation to be reviewed during the inspection. 
Examples of this Spectra/Enbridge documentation is to verify compliance, such as hours of work for employees, field Level Hazard Assessments (FLHA), Job Safety Analysis (JSA), Permits, Key Performance Indicators (KPI's), Learnings from previous incidents and near misses, Daily Equipment Checks, Equipment Log Books and Positive Air Shut Off (PASO) verifications.
Inspectors while in the trailer that the orientation was being conducted identified that the emergency lighting in that trailer was not working. Inspectors requested that Spectra/Enbridge inspect the other trailers to verify the emergency was operating.  Spectra/Enbridge told the inspectors that there were other trailers that lighting that was not operational.  The emergency lighting was corrected that night and inspectors verified that this had indeed been completed.  This was identified as a Corrected Non-Compliance by the inspectors to Spectra/Enbridge and thanked them for their quick response in addressing the Non-Compliance.

Willow Flats Compressor Station (CS 2)
Inspectors, Spectra/Enbridge safety team lead, the Chief Inspector, and Construction Manager drove to the Willow Flats Compressor Station (CS 2).  During the drive along highway 97, appropiate signage and flag persons were observed identifying crews working along the highway.  In addition, mechanical road sweepers were observed keeping the highway clean of mud and debris.  Roadway was very clean and posted speeds were identified as posted and pilot vehicles were escorting the sweepers and were assisted by flag persons.
Inspectors attended a comprehesive site specific orientation by the operator at the station that discussed items such as emergency contact phone numbers, location of life saving devices, muster areas, egress, site hazards, operations being conducted in relation to the Wyndwood pipe install and permitting.  A Safe Work Permit was secured for taking pictures on site.  The inspection group were provide with calibrated 4 head monitors prior to inspecting the site.
When the inspection group proceeded to the site, they were presented individual FLHA's that very very complete and had address and identified the Safe Work Permit (#93531) that the work was being conducted under.
A very large hydrovac operation was being conducted.  Crews had been on site hydrovacing piping, cables structures on the site for approximately three months to identify buried infastructure prior to the Wyndwood pipe install. Hydrovac trucks were identified on site and the documentation for PASO on the hydovac trucks (4 during day and 2 at night) was later examined as satisfactory through document review in the Ledor office.   Hydrovac units are grounded by grounding plates to ground and connected to the truck.
Medic at gate controlled and recorded access/egress and attendance at the CS2 facility. Discussion with the medic determined that there were two mobile treatment vehiles and one ambulance are strategically located throughtout the 27 km of the project.  The medics are primary care certified. Four medics are on days and two are on duty at night when operations are limited.
Safe work was observed and there were no concerns related to the hydrovac operations.

March 20, 2018 Ledcor Yard and Warehouse 55.688024 -121.628957
At the re-fueling stations in the yard, the following was observed as being satisfactory:

Also located in the yard were several different waste bins to provide waste separation.
Cable and material slings were being stored on pallets.  However some slings were laying in the mud and should be totally placed on the pallet to protect the integrity of the sling.  Inspectors indentified this to the Spectra/Enbridge representatives and this was addressed by properly placing the slings on the pallets.  Inspectors noted that this was a Corrected Non-compliance and no further action was required.
Also it was noted that one generator was not properly grounded even though grounding rod was available.  Several other light generators had improper grounding due to rods not being placed solidly into the ground, or connected to non-bare metal on ground rod and/or generator. Inspectors indentified this to the Spectra/Enbridge representatives and this was addressed by properly driving the grounding rods in the earth and properly clamping the contact points.  Inspectors noted that this was a Corrected Non-compliance and no further action was required.
Inspection of the warehouse was conducted.  The warehouse was clean, corridors/access between shelfing unobstructed, and material well organized. No issues or concerns were observed.

March 21, 2018
07:30 Attended Ledcor Construction meeting.
27+000, 26+500, 25+500 (55.61844 -121.85084) Tie in points, Road 15 road bore and Commotion Creek
A skid steer (mobile equipment) was inspected and the operator provided the daily equipment check sheet, along with equipment repair book to the NEB inspectors to check, no issues were observed. NEB inspectors checked several of the workers FLHA cards for competeness and for reference to the Safe Work Permit, and signed on to the cards after review. FLHA was correctly completed and legible. Foremen had a copy of  Emergency Response Plan in their vehicles.
Trucks during backing-up were observed with spotters directing the drivers. Spotters were not observed at any time during this activity to be in the line of fire.
Protective plastic caps were observed to have been placed on vertical ends of temporary fence/barriers and on trucks with vices that had sharp protruding ends, to mitigate against a worker impale type of injury.
Safe engineering check lists for excavation entry was located in tubing holders at sites and conditions were being met.
Welders had flash back protectors installed on acetylene cylinders, and welderswere wearing double eye protection. Grinders had appropiate and complete guards installed.  No issues or concerns were observed.

12+500 West Highway 97 Road Bore (55.6102 -122.0378)
Safe work was observed.  Ladders were properly secured. Two egress runs were in place and solid. NEB inspectors checked several of the workers FLHA cards for competeness and reference to the Safe Work Permit, and signed on to the cards after review. FLHA was correctly completed and legible. Foremen had a copy of the Emergency Response Plan in his vehicle.
A trench box was in use at the hammer head.  Safe work was being conducted with crane operations and safe (mouse traps) were being properly used. 
Good signage and spotters and flaggers were inuse at the site entrance.
Fencing was place were appropiate.
Light towers were in place for  night work as this is a 24 hour operation.
Electrical marker posting (goal posts) were being utilized properly and an air horn was located at the post for spotter signaling.

March 22, 2018 Document Review Ledcor Offices 55.688024 -121.628957
Reviewed Spectra/Enbridge safety program following documentation for the Wyndwood Expansion Project:
>Ledcor Foreman's Safety Kit Wyndwood Expansion Project #7015348
>Pipelayer Training Manual
>Ground Disturbance Permit records (completed samples for 2018, January through March) all permits appeared to be complete:
>>Ledcor, checked for completeness of permit
>> Enbridge, checked/reconciled contractor oversight for review of permits
>Pre-inspection for Supervisor Inspectors truck, unit #D176 was checked, inspection appeared to be in place
>Corrective Action log for all incidents entered in 2018, there were no items observed to be left in pending state (i.e. all action items had been closed)
>Worksite observations and tracking reporting system appeared to be systematic, process driven, and complete
>Joint  Occupational Health & Safety Committee meetings were documented as taking place monthly and co-chairs were in place
>Ledcor Mentorship Program, assessment forms were reviewed (sampling of five workers) and appeared to be in working order
Documentation was readily available for the inspector's review and the inspectors had no issues or concerns.
 

Compliance tool used: Corrected Non-compliance (CNC)

Regulatory requirement:

Relevant section(s):

Company action required:

Company was observed to complete corrective measures for the following identified compliance issues while NEB inspectors were on site:
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Due date: 2018-03-20

Date closed: 2018-03-20
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

Observations (company follow-up 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