Canada Energy Regulator releases pre-construction audit of TC Energy’s Keystone Pipeline GP Ltd. and corrective and preventative action plan
The audit evaluated Keystone’s established processes for managing construction-related safety, emergency, environmental and integrity programs for construction activities.
March 17, 2020
The Canada Energy Regulator (CER) today released its pre-construction audit of TC Energy’s (formerly TransCanada) Keystone Pipeline GP Ltd (Keystone) project. The audit evaluated Keystone’s preparedness to manage construction of its Keystone Project in a way that assures worker safety, protects the environment and prevents incidents.
The CER concluded that Keystone had not yet established, at the time of the audit, all of the necessary oversight measures to manage construction-related safety and environmental protection for the construction of the project.
The company has filed its corrective and preventative action plan (CAPA) which includes analysis of deficiencies, along with proposed methods and timeframes to resolve them. This has been approved by the CER. Keystone must now demonstrate the implementation of their corrective actions portion of their CAPA plan. Once this has been assessed and approved, the company can proceed with construction where requirements have been met.
The CER will continue to monitor Keystone’s implementation of the CAPA, and verify the effectiveness of the company’s management system through targeted compliance verification activities as a part of its ongoing regulatory oversight of the project.
On an ongoing basis, the CER reviews all compliance activities and has the authority to stop work if compliance is not being maintained and to ensure safety and protection of the environment.
The pre-construction audit involved four months of document review and on-site activities, including extensive interviews with company employees and review of internal documents that describe company procedures, training materials, and staff responsibilities.
- The CER maintains a proactive approach to safety and incident prevention and we take all available actions to protect Canadians and the environment.
- The CER reviews the state of all compliance activities on an ongoing basis and has the authority to stop work if compliance is not being maintained.
- Audits are one of the tools the CER uses to assess compliance with its regulatory requirements.
- The CER found 18 non-compliance findings with regulations or conditions of the project Certificate. (Out of 23 protocol questions that were assessed). Most of the deficiencies noted have to do with lack of well-defined processes.
- The CAPA addresses all deficiencies and the CER will continue to review the plan to ensure compliance.
- For all items that were not assessed in this audit, the company must have all required practices in place in order to proceed with construction. The CER, as part of its oversight, will be assessing those areas using other compliance verification activities.
- Canada Energy Regulator (CER) Final Audit Report – TransCanada Keystone Pipeline GP Ltd (Keystone) – Pre-Construction [PDF 1033 KB]
- Corrective and Preventative Action Plan Review by the Canada Energy Regulator
- Keystone Project Requirements and Conditions
- Fact Sheet: Audit Process
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Canada Energy Regulator
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