Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans Mountain Pipeline ULC
Operating company: Trans Mountain Pipeline ULC
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
Field inspection of construction on spread 5A of the Trans Mountain Expansion Project. Focus on watercourse crossings, including reclamation of crossings, implementation of erosion and sediment control measures including flood and high water related impacts as reported in INC2023-071, dewatering and pump-off , wildlife and migratory bird mitigation. Replacement of cryptogamic crust is anticipated in summer or fall.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Watercourse Crossings
Date & time of visit: 2023-06-08 12:00
Discipline: Environmental Protection
Categories:
Facility:
Observations:
Watercourse crossings Mine Creek BC-579, KP 983.90, (fish bearing)
Compliance tool used: No compliance tool used
Observation 2 - CNC 1 BC-577 ESC
On 3 May 2023 TM reported an incident for three separate sites where flooding or spring melt conditions had resulted in adverse environmental effects (INC2023-071), Including at BC-577, KP982.670. At this site, there had been soil sloughing from a grade cut upslope from BC-577. TMEP reported that sediment from the cut-face failure had migrated downslope, along the base of the cut face through diversion berms toward the feature. At the time of inspection, water continued to seep slowly through the cut face, running along the base of the slope, then discharging to the watercourse. The water discharging to the creek was running clear at the time on inspection. One straw wattle had been installed since the slope failure at the bottom of the slope at the creek bank, intercepting the water discharge path, however water was mostly flowing under the wattle. Some of the sediment fencing perpendicular to the RoW had been repaired, thought there was still damaged sediment fence (post event) requiring repair. In the event of rain, there would be little to contain sediment coming from the cut slope along the current drainage path. TMEP representatives confirmed that a slope stability assessment had been conducted and determined it was safe to access the area on foot, but not equipment. The inspection team found that additional erosion control measures were required at BC-577 to prevent additional sediment from entering the watercourse with potential future weather events, particularly along the drainage path from the cut slope. The Inspection Team requested, received and reviewed the TMEP Environmental Incident Investigation report that was initiated for the site. The TMEP representative confirmed the contractor would send a crew experienced in sediment and erosion control to the site to install additional measures.
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Trans Mountain installed check dams and additional straw wattles. Photos provided June 8, 2023, of sediment controls installed to prevent potential sedimentation due to potential rain events.
Due date: 2023-06-08
Date closed: 2023-06-08 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 - General Obsevations
Dewatering/Pumpoff At all sites where pumpoff/dewatering was observed (Coldwater DPI AK 16.1 entry side and exit side, KP 956.650 near NCD BC-550A), the planning, management, oversight and implementation of pumpoff activities was well done, and in accordance with the recently revised environmental field guide (EFG) Pumpoff. Approved plans were in place, monitoring was demonstrated through tracking sheets, and notably at the Coldwater DPI South (approx. AK 16) the crew had implemented the required water quality monitoring when it was observed that pumpoff water may reach the Coldwater River. Housekeeping and Leak/Spill response At approximately KP 956.650, the Inspection Team observed TMEP and contractors taking appropriate measures to respond to a dripping backhoe. Contractor personnel noticed the drips, stopped the equipment, and initiated response. Response included placing a drip tray and sorbent under the leak, requesting a mechanic to repair, and beginning shovelling the impacted soil, which included a relatively long trail of small drip marks. The equipment remained parked where it had been stopped until the mechanic could arrive. The response was well done. In general, at all sites inspected, housekeeping was well done. There was no garbage or construction debris, soil stockpiles were marked, signage was in place. Safety At KP 956.650, observed a worker riding a UTV with a helmet on, but with the strap not fastened. Raised this with the worker who buckled the strap. In addition, Trans Mountain included a reminder about the requirement to review the UTV JSA prior to work, wear and fasten the helmet and also wear the seatbelt in the subsequent safety bulletin. Stickers – raised observations of potentially problematic stickers observed, Trans Mountain to determine whether they were in accordance with Trans Mountain’s requirements. ML/ARD
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
