ARCHIVED - Westcoast Energy Inc. carrying on business as Spectra Energy Transmission - Letter regarding Safety Order SG-W102-002-2015

Westcoast Energy Inc. carrying on business as Spectra Energy Transmission - Safety Order SG-W102-002-2015 [PDF 254 KB]

Corrective Action Plan - Details, analysis and milestones template [EXCEL 62 KB]

OF-Surv-FIns-W102-2014 01
9 March 2016

Mr. Mark Fiedorek
President
Spectra Energy Transmission West
Suite 2600, 425-1 Street S.W.
Calgary, AB  T2P 3L8
Facsimile

Dear Mr. Fiedorek:

Westcoast Energy Inc. carrying on business as Spectra Energy Transmission (Westcoast)
Safety Order SG-W102-002-2015 (Safety Order)

On 14 July 2015, the Board (NEB or Board) issued the Safety Order to address a number of concerns with respect to the operations at Westcoast’s processing plants and facilities.

In accordance with the terms of the Safety Order, Westcoast submitted the following documents for approval of the Board on 14 August 2015, 30 September 2015 and 30 October 2015, respectively:

• Staffing Reports for all Westcoast processing plants and facilities with the exception of the McMahon Gas Plant (Condition #2 of the Safety Order);
• A report related to Westcoast’s management system and corrective action plan (Report) (Condition #1 of the Safety Order); and
• Staffing Report for the McMahon Gas Plant (Condition #3 of the Safety Order).

On 22 December 2015, Westcoast filed additional information with the Board in response to an NEB Information Request (IR). The IR response included more detailed and supplemental information related to the Report.

The Board has reviewed the Staffing Reports filed pursuant to Conditions #2 and #3 of the Safety Order and has not identified any issues; therefore, the Board is of the view Westcoast has satisfied these Conditions.

With respect to Condition #1, the Board has reviewed the information filed by Westcoast and is of the view that Westcoast has satisfied Condition #1 c, d and e of the Safety Order. However, Condition #1 a and b remain outstanding, since the information submitted by Westcoast was insufficient to demonstrate, through a root cause analysis, where the breakdowns or failures occurred in the implementation of Westcoast’s management system or how and by what date Westcoast will correct these breakdowns or failures. The Board continues to require confirmation that Westcoast has addressed links to management system elements within its proposed corrective actions. Accordingly, the Board directs Westcoast to complete and file with the Board, the attached template correlating cited non-compliances with immediate and basic root causes and management system element deficiencies by 22 April 2016.

The Board has asked NEB technical staff to be available to meet with Westcoast to answer any questions concerning the completion of the attached template. To schedule this meeting, please contact Ryan Wells, Compliance Program Manager, Safety Management at 403-909-4655.

Yours truly,

Original signed by

Sheri Young
Secretary of the Board

cc: Mr. Greg Ebel, Chairman, President and Chief Executive Officer, Facsimile
Ms. Michele Harradence, Vice President, Operations & EHS, Facsimile
, AGC and Director, Regulatory Compliance & Audit, Facsimile

Attachments

• NNC Corrective Action Plan (CAP) Template Guidance
• NNC details, Analysis of the NNC and CAP milestones

NNC Corrective Action Plan Template Guidance
Attachment to Board letter dated 9 March 2016

NNC Corrective Action Plan (CAP) Template Guidance - for Westcoast
Safety Order SG-W102-002-2015 issued 14 July 2015 (Safety Order)
File OF-Surv-Fins-W102-2014 01

As per the attached cover letter, the Board requires more detailed information regarding the causes of the Notices of Non-compliance (NNCs) related to the Safety Order and that Westcoast provide additional details regarding its proposed CAP. The information requested will allow the Board to determine whether Westcoast has fully analyzed the causes and deficiencies of the NNCs and ensure that Westcoast develops and implements Corrective and Preventive Actions (CAPA) within its proposed CAP in a timely manner that address the identified NNCs. The template outlines the format and type of information required by the Board to complete its analysis of Westcoast’s CAP.

In order to facilitate review, please aggregate the non-compliances where appropriate.

Please note that all commitments to actions and deliverables made herein are subject to approval by the Board and therefore any alterations or deviations from timelines and/ or deliverables must also be approved by the Board prior to implementation of the variances.

The template consists of three worksheets:

1. NNC Details;
2. Analysis; and
3. CAP Schedule.

Sheet 1 NNC Details:

• NNC# - The file number(s) of the NEB issued NNCs being addressed (The company is encouraged to aggregate the NNCs where the NNCs represent repeat or identical issues with identical causes)
• Location - The location(s) where the non-compliance was identified.
• Finding/ Description of Deficiency - The entire description of the deficiency or non-compliance as written in the NNC.
• Related Legal Requirement(s) - As identified in the NNC and as identified as part of the issue analysis by the company.
• Affected Program Owner - Include the program and position title of the person that is accountable for the resolution of the NNC (for example, Vice-President Operations). If the issues relate to the OPR, the expectation as set out in the OPR is that the accountable person would be the Accountable Officer. If the issues relate to other requirements, the expectation is that the Affected Program Owner would conform to the requirements of the Accountable Officer identified in subsection 6.2(3) of the OPR.

Sheet 2- Analysis of the NNC:

• Direct / Immediate Cause(s): All identified unsafe acts or conditions that resulted in or could have resulted in an accident. List all that apply. (This requirement mirrors the NEB Event Reporting System requirements.)
• Root or Basic Cause(s): The most fundamental cause that can be reasonably corrected to prevent recurrence of the accident, finding or non-compliance. List all that apply. (This requirement mirrors the NEB Event Reporting System requirements.)
• Requirements set out in Schedule A to the Safety Order:
  After completing the analysis of the non-compliance, identify the process(es) or requirement(s) as listed in Schedule A to the Safety Order, that have been identified as deficient. This should be undertaken by systematically examining each Schedule A requirement and identifying the specific deficiencies within each. This may result in more than one deficiency in any given Schedule requirement. In analyzing the deficiencies, consideration must be given to the “linkages” between management system elements. Therefore, an NNC may have multiple Schedule A causes. For example, inadequate documented procedures may be as a result of deficient risk analysis, risk control development, document control and internal auditing processes.
• Corrective Action: Describe actions proposed or taken for each NNC at the time to prevent the specific deficiency from resulting in immediate harm at the location described.
• Preventive Action: Describe actions proposed or taken as a long term solution to prevent recurrence of the deficiency and /or multiple instances. When identifying the Preventive Actions required to address Schedule A requirements, consideration must be given to the “linkages” between management system elements. Therefore, an NNC may have multiple Schedule A actions. For example, implementing an updated risk analysis process may result in actions required in multiple Schedule A areas such as management of change, document control, document control, inspection and internal audit processes.
• Description: how the proposed corrective and preventative actions address the non-compliance noted or deficiency identified. Describe how the CAP will prevent recurrence at the site identified and measures in place to prevent this deficiency at another Westcoast site.
• Summary of the CAPA: Provide the conclusions of Westcoast’s analysis by describing the proposed Desired End Result (DER) associated with each corrective or preventive Action proposed.

Sheet 3 - CAP milestones:

• Quarterly Deliverables: Describe the significant targets within the CAP development and implementation that will be met in order to demonstrate and ensure timely implementation of the CAP. Westcoast should justify the stages and schedules for milestones and include any anticipated outputs.
• Date of filing (dd-mm-year): For each deliverable, Westcoast must file documentation to demonstrate its progress in CAP development/implementation.
• Target date for CAP completion:dd-mm-year
• Rationale for Schedule: Explain and justify the proposed CAP schedule and completion dates.

Notices of Non-compliance Details, Analysis and CAP Schedule
Attachment to Board letter dated 9 March 2016

NNC details, Analysis of the NNC and CAP milestones

NNC Details

Analysis of the NNC

CAP Milestones

Date modified:

2021-02-22